CMS Update - AHFSA

CMS Update - AHFSA

Division of Nursing Homes LTC Survey Process and Phase II Requirements AHFSA Annual Conference Orlando, Florida August 22, 2017 For Official Federal Government Use Only This pre-decisional, privileged, and confidential information is for internal government use only, and must not be disseminated, distributed, or copied to persons not authorized to receive the information.

Unauthorized disclosure may result in prosecution to the full extent of the law Agenda

New Survey Process Phase II Interpretive Guidelines Training Enforcement / Five Star Quality Rating System State Performance Standards System Q&A 3

Long Term Care Survey Process (LTCSP) Begins November 28, 2017 (includes Phase 1 and 2 requirements) Lessons learned from the Traditional and Quality Indicator Survey (QIS) processes

Best practices and opportunities for improvement Identified slightly different quality of care/quality of life issues Flexibility vs. prescriptiveness Computer-aided vs. paper-based Conference room vs. out and about Integrate finalized Requirements for Participation

Survey Process Overview Entrance Process Sample Selection (size based on census) 70% offsite 30% selected onsite by team Screens Initial Pool Final Sample Facility Tasks and Closed Record Reviews Investigations

All concerns for sample residents requiring further investigation 6 Entrance Conference Census and list of all residents, with identification of new admissions Documents Previous process (e.g., floor plan, CMS 671/672, etc.) Policies and Procedures

New requirements (QAPI plan, Facility Assessment) Meal and medication administration times Access to Electronic Health Records Updated facility matrix Facility Matrix 9

Sample Selection Surveyors screen all residents in their assigned area. Prioritize vulnerable residents, new admissions, complaints/facility reported incidents (FRIs), and other issues identified throughout the day. Initial Pool: Conduct interviews, observations, and limited record review ~8 residents/surveyor Offsite, preselected residents Residents identified onsite as a result of screens (prioritized by new admissions, vulnerable residents)

Facility Matrix used to identify other specific concerns(e.g., dialysis, hospice, smoking, ventilator, infection, etc.) Final Sample: Based on facility census (~20%) 70% offsite/30% onsite End of day 1/start of day 2 11

12 Complaints & Facility Reported Incidents (FRI) Issue: Balancing efficiency and protecting the integrity of the process Analysis: ~30% of standard surveys included complaints

Of surveys with complaints, 94% included no more than five complaint residents Policy: States may add up to five residents associated with a complaint or FRI If more than five residents are added to the sample, team size or survey time is extended Continuous monitoring and dialogue

13 Mandatory Facility Tasks Sufficient/Competent Staffing Infection Control Beneficiary Notices Dining Observation Medication Storage

Medication Administration Kitchen Observation QAA/QAPI Interpretive Guidelines (IG) Revised format with consistent sections (e.g., Key elements of Non-compliance) Most of the IG has not been changed Revisions for phase 1 & 2 tags, and some existing

tags where improvements were needed Revised CE pathways based on lessons learned (e.g., MDS focused surveys) 16 17 18

F-Tags 19 F-Tag Crosswalk 20

Number of Surveyors & Time Onsite Census < 48 49 - 95 96 - 174 175 Sample Size < 12

13 - 19 20 - 34 35 % of Census > 25% 20% 27% 20% < 20%

# of Surveyors 2 3 4 5 Survey time onsite is expected to be similar to current time spent onsite

Expect some lengthening while surveyors learn the new process Number of surveyors and time onsite also impacted by other factors such as State licensure, facility history, or complaints Continuous monitoring and dialogue 21 22

State Surveyor Training Scheduled Attendance: State trainers: Conducted 7/31 8/4 & 8/7 8/11 (East/West coast) Weekly regional and make-up training sessions: August October ASPEN Coordinator Training: Late August/Early Sept (Longmont, CO) On-demand Training:

State management: Overview of new process and implementation Subject Matter Expert Videos: Phase II Highlights Computer-Based Training: Software functionality The sand-box: Available in September (Practice, Practice, Practice!) 23 Integrated Surveyor Training Website

24 25 Readiness Pre-November 28: Project plan, checklist, and equipment (Admin-info 17-21-NH) Manager support and training completion (including monitoring

for completion) Practice, practice, practice! How will I know Im prepared? Post-November 28: Monitor findings, trends, and outliers How will I know care-related issues are not being missed? What are my trends and outliers? Why do they exist? What is within my control, and outside? Communicate with colleagues, AHFSA, and CMS.

Focus on intent! 26 Provider Training Training available through ISTW Specific provider training Survey documents Entrance worksheet

Facility Matrix Procedure guide Frequently Asked Questions 27 28 Enforcement/ Five Star Implications

Phase II Enforcement: Focus on education for phase II requirements (e.g., facility assessment, antibiotic stewardship, etc.) Directed Plan of Correction, directed in-service training Enforcement of Phase I requirements remains unchanged Five Star Quality Rating System: Surveys conducted using the new survey process not included in five star quality rating system Apples to Apples comparison

Transparency and user-friendliness to consumers (See S&C 17-36-NH) 29 State Performance Standards System (SPSS) Long Term Care Measures FY 2017 Q9 Waived

FY 2018 SPSS requirements remain in effect Balance expectations: Flexible due to new process and requirements Ensure noncompliance is identified and resident safety Analyze performance for FY 2018 SPSS decisions (expectations and consequences)

Questions and Comments

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