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Nursing Home Round Table��November 5, 2024�

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Stakeholder and Agency Updates

Dora
HCPF
CHCA
Ombudsman Program
Leading Age
Telligen
Dementia Partnership
Others

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Presentation

MORE GUIDANCE FOR

Enhanced Barrier Precautions

Marlee Barton, HAI/AR Infection Prevention Nurse Consultant

DCEED

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Section Updates

Recent hires leaves 6 open positions
Dedicating staff to address increase in complaints has nearly resolved backlog.
Dedicating staff to address the enormous amount of reported FRIs has reduced overdue triage and subsequent investigation by nearly half.
Presently there are 10 facilities that are overdue (beyond 15.9 mos.) with the oldest at 17.65 months since last recertification exit.

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Citations in Rank Order-FFY 24

Nation	Colorado
F884 – NHSN Reporting	F884 – NHSN Reporting
F880 – IPCP	F880 – IPCP
F689 – Accident Hazards/Supervision	F689 – Accident Hazards/Supervision
F812 – Sanitary Food Service	F761 – Medication Storage
F684 – Quality of Care	F600 – Free from Abuse and Neglect
F656 – Comprehensive Care Plan	F812 – Sanitary Food Service
F761 – Medication Storage	F677 – ADL Care for Dependent Res.
F677 – ADL Care for Dependent Res.	F684 – Quality of Care
F609 – Reporting Alleged Violations	F695 – Respiratory Care
F600 – Free from Abuse and Neglect	F584 - Environment

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Citation Frequency Report

Citation	# Citations	% Providers Cited	% Surveys Cited
F884-NHSN Reporting	224	34.6	34.6
F880-IPCP	102	40.7	15.7
F689-Accident Hazards	75	29.9	11.6
F761-Medication Storage	65	28.5	10.0
F600-Free from Abuse and Neglect	63	22.4	9.7
F812-Sanitary Food Service	61	25.7	9.4
F677-ADL Care for Dependent Res	46	15.4	7.1
F684-Quality of Care	42	17.8	6.5
F695-Respiratory Care	33	13.1	5.1
F584-Environment	31	12.6	4.8
F686-Prevent/Heal P.U.	31	14.0	4.8

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Common Complaints FFY 24 (no particular order)


DC Appeals/Refuse to readmit/DC notice	Staffing/Call lights
Choices/Dignity	Physical abuse/neglect/missing property
Environment/temperatures/pests	Wound Care
Weight Loss	Food quality
Medications not available/Over medicated	Falls with Injury/elopement
Showers/hygiene/ADLs	Untreated pain
Notification of change of condition	Outbreaks

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REVISITING DISCHARGE REQUIREMENTS

Recent uptick in DC complaints/appeals and citations.
Mandatory CMS Review of all DC citations has resulted in an increased emphasis transfer and discharge requirements) and permitting residents to return to the facility and has led to surveyor guidance that It’s not just the notice (F623).
Ongoing discussion at CMS may result in fewer discharge F-tags and provide clarity to citing the appropriate regulation. Fewer regulatory numbers will not result in fewer requirements.
2021 OIG report placed a spotlight on facility-initiated discharge. Enhanced CMS enforcement for Inappropriate facility-initiated discharges.

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Discharge-related Regulations

F622 – Transfer and Discharge Requirements
F623 – Notice before Transfer/Discharge
F624 - Preparation for Safe/Orderly Transfer/Discharge
F625 – Notice of Bed Hold Policy Before/Upon Transfer
F626 – Permitting Residents to Return to the Facility

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Discharge Critical Element Pathway

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FAQs and Discussion�(or Help Chad Reply to Emails)�

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September – November 2024

Guardians wants secured neighborhood placement despite assessment. See Chapter 5, Section 23.
Increase in antipsychotic medication use in Colorado Nursing Homes following COVID-19 pandemic. Detailed report: https://qioprgram.org/tools-resources/antipsychotic-use-state.
Antipsychotic injections leads to questions: Is it the most effective and acceptable route, does the technique meet current standards of practices including injection safety, are standard infection prevention precautions followed, are the requirements in F758 being met?

FAQ: Part 1

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September – November 2024

How can do an immediate discharge to a homeless shelter? Determine, based on no other discharge locations are available and the assessed needs of the resident that the discharge will be safe e.g., self care, compatible history, access to needed services and resources. Ensure assessments, coordination of care notes and physician discharge documentation is in place.
Immediate discharge for AMA. Discharges that appear to be resident initiated may in fact be facility initiated based upon the circumstances. e.g., feeling there is no other alternative, assumed communication through behavior, etc.

FAQ: Part 2

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September – November 2024

Clarifying Federal reporting requirements: Immediately but not later than 2 hours if the alleged violation involves abuse OR serious bodily injury. Not later than 24 hours if the alleged violation involves neglect, exploitation, or misappropriation of resident property; and did not result in serious bodily injury.
Where can I find information about nursing homes and surveys: Medicare.gov/care-compare.
Questions about nurse delegation-Please contact DORA.

FAQ: Part 3

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September – November 2024

Family insists on providing wound treatment while resident is at facility:

There is nothing in the SOM that clearly addresses this situation. The facility and the family member should meet and agree (in writing) about how the wound care will be provided. An acceptable example would be for the family to do wound care with a nurse observing. The nurse would verify acceptable technique and document an assessment of the wound. If the wound appears to be deteriorating, the physician who gave the treatment orders and the Medical Director should be notified. The facility is responsible to provide all other treatment interventions e.g., pressure reducing techniques, turning, mattress, cushions, and nutritional interventions.

FAQ: Part 4

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Questions?