Skilled nursing facilities are counting down to Nov. 28, when a new survey process will begin.
The updated survey is part of the sweeping regulatory overhaul that began to take effect in November 2016, with implementation to occur in three phases. The new survey is part of the second phase, and it includes a number of notable changes, including new F-tags.
While preparing for the coming changes requires a thorough educational and training push, here are three areas of focus for providers to keep in mind, as emphasized by survey experts Monday at the American Health Care Association’s annual conference in Las Vegas.
1. Smoking under scrutiny
Facilities need to carefully consider how they handle smoking, considering that smoking policies will now be its own F-tag, said Joan Redden, senior expert nurse reviewer at JR & Associates LLC.
“When [surveyors] walk into your building, they’re going to ask for your list of smokers, and what your smoking policy is and the posted hours,” she said.
In particular, this can be a challenge in buildings with large populations of younger residents, she noted. If a facility is officially non-smoking but allowing residents to go off premises to smoke, that policy should be reconsidered. If a resident experiences an injury while smoking, the facility would still own that outcome, Redden stated.
In a building she was overseeing, Redden sometimes had therapists accompany residents outdoors to lead them in rehab exercises while they smoked, as a method of supervision.
“I don’t know if this is a great idea, but it worked for me,” she said.
2. Tune in to resident satisfaction
Surveyors will now have more latitude in the types of questions they ask residents about their experiences and level of satisfaction.
“They can look at, what has the resident council been talking about, and [they can ask] has the facility tried to fix those things that you’ve expressed as a concern?” said Steve Biondi, president of consultancy Biondi and Associates. “Beyond having minutes, we have to make sure that we’re documenting some resolution or efforts to address those issues.”
Leaders need to be sure they’re tuned in to how satisfied their residents are, to avoid unpleasant surprises when the surveyors arrive, said Redden.
“I had probably the worst survey of my life where they went into a resident council meeting and it was over two-and-a-half hours,” she said. “… If people are that unhappy and miserable, I want to know about that.”
Meeting with the resident council weekly is a smart idea to address continuing or serious dissatisfaction, she advised.
3. Rely on Critical Element Pathways
The Centers for Medicare & Medicaid Services (CMS) has issued Critical Element Pathways, providing the framework that surveyors will use to evaluate facilities in key areas such as medication administration, dementia care, hospitalization and pain management.
Skilled nursing providers should turn to these as the essential guides to ensure they’re up the mark when the new surveys begin, Redden stressed. Not doing so would be like studying the wrong materials for a college class and then failing it, she said.
“Please, please, please use your Critical Element Pathways,” she said. “Use the same processes as the surveyors.”
Written by Tim Mullaney
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