FSSA Releases Draft Report Concerning Managed Care for the Indiana Medicaid Aged, Blind and Disabled Population

FSSA released a draft Aged, Blind and Disabled Managed Care report that is due to the General Assembly on December 15th (click here for the draft report).  The report concludes that neither Risk Based Managed Care nor Managed Fee For Service would result in savings for the State if all ABD groups were enrolled in either program (see Table 31, page 73). 

The report provides several scenarios of carve-outs (exclusions) to each program in order to realize a savings to the State, including carving-out nursing facilities.  The report also indicates that Risk Based Managed Care and Managed Fee For Services provide high potential for improved care coordination and availability of enhanced services since those services would not be tied to the State Plan Amendment.  The report specifically includes discussion of carving-out nursing facility (institutional) care, and details concerns with loss of UPL supplemental payments and QAF payments.

Once the final report is issued, IHCA will ensure it is distributed to members.  Contact Zach Cattell at zcattell@ihca.org or 317-616-9001 with any questions.

HHS OIG Releases Report Recommending a New QM for Rehospitalization Rates

The HHS Office of Inspector General (OIG) released a report last month (click here for the report) that recommends CMS develop a quality measure describing nursing home rehospitalization rates and instruct State Survey Agencies to review that quality measure as part of the survey process.  In 2011, the OIG found that 25% of nursing home patients were transferred to hospitals for inpatient admissions, which cost $14.3 billion to the Medicare program.  They also found that readmission rates varied widely across nursing homes.  The OIG is concerned that readmissions increase risk of residents’ experiencing harm and negative care outcomes.

OSHA Revises Hazard Communication Standard

OSHA has revised its Hazard Communication Standard to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals.  All nursing centers and assisted living centers must train staff on this new standard by December 1, 2013.  Click here for a summary of the training requirements and a brief power point presentation that can be used in the required training.  These were prepared by Jackson Lewis LLP, AHCA’s OSHA consultant.  A summary of the OSHA Final Rule related to these changes can be found here.

CMS Memo Concerning Full Sprinklering of Nursing Centers

This is the latest CMS memo concerning full sprinklering of nursing facilities and includes actions that a nursing center may take to substantially lower exposure to fire risks while a sprinkler system is being installed.  As well, there is additional information related to enforcement actions that may be taken when a nursing center has not met the required deadline for full sprinklering, and an update Question and Answer document about full sprinklering.  Indiana required full sprinklering for nursing facilities prior to the Federal requirement, so this memo is mostly for your general information and awareness.

ISDH Residential Survey Update

There were 62 offense and deficiency citations issues to residential care facilities in October, a high for 2013.  14 of the citations were offense and 48 were deficiency.  The total number of citations was increased in part due to the federal government shutdown as surveyors completed more annual surveys of residential care facilities that would otherwise have occurred.  Leading the way in October were Tags 241 and 273, each of which were cited 10 times.  Tag 241 is issued for failures to have physician ordered medications administered by licensed nursing personnel or by QMAs, and Tag 273 is issued for failures maintaining food preparation and service areas in accordance with state/local sanitation and food handling standards.  The next most frequent tag for October was Tag 144, cited 6 times, concerning maintenance of grounds in a clean and orderly manner.

Click here to view a summary of the October residential care facility offense and deficiency citations.

ISDH IJ/SSQC Update

There were 2 events in the month of October that led to 1 citation that was SSQC only and 2 citations that were IJ and SSQC.  Reaching back to a frequent issue in 2012, unsafe hot water temperatures were found in a facility and resulted in F323 being cited (SSQC only).  The facility was aware of the water temperature issue due to a faulty water heater, that was replaced, and a newly-installed mixing valve.  However, these remedies did not solve the hot water problem and several residents were aware of it and had reported it to staff.  The Administrator knew the maintenance director was checking the water temperatures, but was not aware that a log was not being maintained to check for patterns.  Temperatures exceeded the 120-degree limit, and at some faucets water more than 150, 160 and 180-degrees Fahrenheit.

The other October event concerned an allegation of abuse and the failure to ensure timely reporting of the allegation to the Administrator and the ISDH. This event led to two citations, F225 and F226, at the IJ and SSQC levels.  There was an allegation that a CNA had tied a resident’s gown to the resident’s wheelchair on 10/1/13, but the incident was not reported to the DON until 10/2/13 and it also did not reach the Administrator until 10/4/13.  The accused CNA was seen manipulating the resident’s gown on surveillance tape, and continued to work until the Administrator received the report.  A second CNA appeared to be aware of the alleged abuse, did not report it, and also was still working until the Administrator received the report.    The ISDH was notified via incident report the same day the Administrator was made aware of the issue, but this was 3 days after the alleged abuse was known to staff.

Click here to view a summary of 2013 IJ/SSQC citations and for the citations from October.