IHCA
As reported previously by AHCA and IHCA, TMF Health Quality Institute is contracted with the Centers for Medicare & Medicaid Services (CMS) to produce and distribute the Program for Evaluating Payment Patterns Electronic Report (PEPPER). To date, PEPPERs have been available electronically to SNFs/swing bed units of short-term acute care hospitals. Other SNFs have received their PEPPER in hard-copy format via mail.
TMF is currently developing a secure portal on its website to deliver PEPPERs to SNFs that do not have access to QualityNet. TMF anticipates the PEPPERs will be made available for download in May 2014; and they will remain accessible for approximately one year. To receive notification when the PEPPER is available and guidance on accessing the PEPPER, join the email list at http://www.pepperresources.com (see the gray box on the upper right section of the Home page).
Please note these requirements:
1. Access to the PEPPER will be restricted to the provider’s Chief Executive Officer, President or Administrator. Note: Corporate offices and/or facility management companies will need to obtain PEPPERs from each individual provider in their organization.
2. Requestors will be required to enter their 6-digit CMS certification number (also referred to as a provider number or PTAN) (third digit of “5” or “6” for SNFs). This is *not* the same number as the tax identification number or national provider identification number.
3. For verification purposes, requestors will be required to enter either a medical record number *or* a patient control number for a patient who received services at the provider during a specified time period (TMF will determine this time period closer to report distribution).
Note: Only numerical entries can be accepted. If providers use only letters in both of these fields they must contact TMF to request assistance. Patient names cannot be entered due to patient privacy laws.
This will not impact providers who receive their PEPPER via QualityNet. SNFs/swing bed units of short-term acute care hospitals will continue to receive their PEPPER via QualityNet. These providers will be notified via email once the QualityNet distribution is complete. Visit http://www.pepperresources.com for more information about PEPPER or to submit questions about PEPPER
Monday, February 3, 2014
SNF Value-Based Purchasing Demonstration Evaluation Report
On the Medicare side of life, CMS launched a demonstration in 2009 concerning Value-Based Purchasing in three states – Arizona, New York and Wisconsin. The initiative was designed to test whether improvements in quality of care for Medicare beneficiaries could be achieved. Last August, L&M Policy Research and Harvard University released a report (click here) that evaluated the demonstration. AHCA’s Elise Smith, Senior Vice President of Finance Policy and Legal Affairs, provided the following summary of the report:
The Nursing Home Value Based Purchasing (NHVBP) Demonstration is part of the Centers for Medicare & Medicaid Services’ (CMS) initiative to improve the quality of care for Medicare beneficiaries in nursing homes. The demonstration was launched in July 2009 and implemented by Abt Associates, Inc. (Abt), under contract with CMS. The three-year, demonstration tested the concept of value-based purchasing in nursing home settings in three states – Arizona, New York and Wisconsin.
For each state, Abt had ranked facilities by performance scores, which determined the annual distribution of payments. Reflecting the overall budget neutrality requirement for the demonstration, payments in each state were contingent on treatment facilities generating cost savings relative to the performance of a comparison group in each state through the reduction of avoidable hospitalizations and other costs.
L&M Policy Research (L&M) and Harvard, the consultants contracted to conduct an evaluation of the NHVBP demonstration, concluded that the demonstration did not directly lower Medicare spending and improve quality for nursing home residents.
CMS directed that the evaluation address the following questions:
• How does the pay-for-performance concept work within the nursing home setting?
• How has the demonstration impacted nursing home quality, cost, service delivery, resident outcomes, organizational structure, and financial status?
• How do participating homes compare to non-participating homes?
Results
Over the entire three-year demonstration period, savings were realized in Arizona (Year 1) and Wisconsin (Years 1 and 2); no savings were generated in Arizona (Years 2 and 3), New York (Years 1-3), and Wisconsin (Year 3). Thus, only three of the nine NHVBP state-year evaluation periods resulted in payments to the top performing nursing homes. The Year 1 savings in Arizona were relatively modest, while the Year 1 and Year 2 savings in Wisconsin were more.
However, in its evaluation of quality relatively few outcomes suggested major pre-post performance differences across the treatment and comparison groups. Based on its analysis, L&M concluded that quality was unchanged due to the NHVBP demonstration.
• Officials in all three states explained that many decisions and actions, even those in quality domains targeted by the demonstration, were most likely attributable to the increasing pressures, independent of demonstration incentives, to contain costs and improve quality in response to health care reform.
• L&M heard very little to suggest that nursing homes responded to the NHVBP demonstration incentives through direct interventions.
In combining the quantitative and qualitative results, L&M concluded that the NHVBP demonstration did not directly lower Medicare spending and improve quality for nursing home residents. Two important questions emanate from this conclusion.
• First, how did Arizona (Year 1) and Wisconsin (Year 1 and 2) generate savings if nursing homes generally did not explicitly act in response to the NHVBP demonstration?
• And second, why did the treatment facilities appear to not respond to the payment incentives under the NHVBP demonstration?
L&M surmised that the answer to the first question might relate to the design of the NHVBP demonstration. New York was the only state in which facilities that applied to participate were randomized across the treatment and comparison groups. Thus, the observed savings in Arizona and Wisconsin may reflect differences in facilities that comprised comparison groups selected by propensity scores in these respective states. Indeed, the difference in base-year spending for long-stay residents between the treatment and comparison facilities was much larger in Arizona and Wisconsin than in New York.
Regarding the second question, nursing homes may have altered their behaviors under the NHVBP demonstration for a variety of reasons.
• First, the demonstration had a very complex payment and reward system and nursing homes may not have understood how their efforts towards improving quality would result in a better performance score and ultimately a reward payment.
• Second, because CMS had a savings threshold of 2.3 percent and an 80 percent sharing rule, the payouts under the demonstration may have been too small to incentivize major changes in quality.
• Third, because a payout was only made if the treatment nursing homes generated savings relative to the comparison homes in that state-year period, many nursing homes may have decided not to act in direct response to the NHVBP because their likelihood of a payout depended on other nursing homes in the state also generating savings.
• Fourth, due to the use of administrative data to determine savings and performance, the sharing of performance reports and payouts to top performing nursing homes took nearly 18 months. This may have lowered the salience of any potential rewards to treatment facilities.
• Fifth, many nursing homes may have lacked the infrastructure and expertise to engage in quality improvement innovation on their own.
Finally, rather than being incented to change practices because of the possibility of a payout, many facilities saw the demonstration as a reinforcement of actions they were already planning to take or had already begun implementing. Most nursing homes did not change their actions because of the demonstration; rather, some hoped to be rewarded for things that they were already doing or thought their involvement in the demonstration would just be an opportunity to learn from other nursing homes, or prepare for what is to come from CMS moving forward.
Although the NHVBP demonstration was found to have a minimal direct effect on quality, L&M concluded that this result may say more about the specific design features of the demonstration rather than the actual potential of nursing home pay-for-performance.
L&M Recommendation:
If the Medicare program chooses to move forward with the pay-for-performance concept in the nursing home setting, it should consider changes to optimize the response to payment incentives to improve quality. Modifications to the design of any future NHVBP program might include:
• Simplified payment and reward rules;
• Increased payout pools;
• Relaxation/elimination of budget neutrality restrictions such that the likelihood of payout does not hinge on the efforts of other participating facilities;
• Offering more immediate payouts;
• Real time feedback on performance and quality activity results; and providing increased education and guidance on best practices to providers.
The Nursing Home Value Based Purchasing (NHVBP) Demonstration is part of the Centers for Medicare & Medicaid Services’ (CMS) initiative to improve the quality of care for Medicare beneficiaries in nursing homes. The demonstration was launched in July 2009 and implemented by Abt Associates, Inc. (Abt), under contract with CMS. The three-year, demonstration tested the concept of value-based purchasing in nursing home settings in three states – Arizona, New York and Wisconsin.
For each state, Abt had ranked facilities by performance scores, which determined the annual distribution of payments. Reflecting the overall budget neutrality requirement for the demonstration, payments in each state were contingent on treatment facilities generating cost savings relative to the performance of a comparison group in each state through the reduction of avoidable hospitalizations and other costs.
L&M Policy Research (L&M) and Harvard, the consultants contracted to conduct an evaluation of the NHVBP demonstration, concluded that the demonstration did not directly lower Medicare spending and improve quality for nursing home residents.
CMS directed that the evaluation address the following questions:
• How does the pay-for-performance concept work within the nursing home setting?
• How has the demonstration impacted nursing home quality, cost, service delivery, resident outcomes, organizational structure, and financial status?
• How do participating homes compare to non-participating homes?
Results
Over the entire three-year demonstration period, savings were realized in Arizona (Year 1) and Wisconsin (Years 1 and 2); no savings were generated in Arizona (Years 2 and 3), New York (Years 1-3), and Wisconsin (Year 3). Thus, only three of the nine NHVBP state-year evaluation periods resulted in payments to the top performing nursing homes. The Year 1 savings in Arizona were relatively modest, while the Year 1 and Year 2 savings in Wisconsin were more.
However, in its evaluation of quality relatively few outcomes suggested major pre-post performance differences across the treatment and comparison groups. Based on its analysis, L&M concluded that quality was unchanged due to the NHVBP demonstration.
• Officials in all three states explained that many decisions and actions, even those in quality domains targeted by the demonstration, were most likely attributable to the increasing pressures, independent of demonstration incentives, to contain costs and improve quality in response to health care reform.
• L&M heard very little to suggest that nursing homes responded to the NHVBP demonstration incentives through direct interventions.
In combining the quantitative and qualitative results, L&M concluded that the NHVBP demonstration did not directly lower Medicare spending and improve quality for nursing home residents. Two important questions emanate from this conclusion.
• First, how did Arizona (Year 1) and Wisconsin (Year 1 and 2) generate savings if nursing homes generally did not explicitly act in response to the NHVBP demonstration?
• And second, why did the treatment facilities appear to not respond to the payment incentives under the NHVBP demonstration?
L&M surmised that the answer to the first question might relate to the design of the NHVBP demonstration. New York was the only state in which facilities that applied to participate were randomized across the treatment and comparison groups. Thus, the observed savings in Arizona and Wisconsin may reflect differences in facilities that comprised comparison groups selected by propensity scores in these respective states. Indeed, the difference in base-year spending for long-stay residents between the treatment and comparison facilities was much larger in Arizona and Wisconsin than in New York.
Regarding the second question, nursing homes may have altered their behaviors under the NHVBP demonstration for a variety of reasons.
• First, the demonstration had a very complex payment and reward system and nursing homes may not have understood how their efforts towards improving quality would result in a better performance score and ultimately a reward payment.
• Second, because CMS had a savings threshold of 2.3 percent and an 80 percent sharing rule, the payouts under the demonstration may have been too small to incentivize major changes in quality.
• Third, because a payout was only made if the treatment nursing homes generated savings relative to the comparison homes in that state-year period, many nursing homes may have decided not to act in direct response to the NHVBP because their likelihood of a payout depended on other nursing homes in the state also generating savings.
• Fourth, due to the use of administrative data to determine savings and performance, the sharing of performance reports and payouts to top performing nursing homes took nearly 18 months. This may have lowered the salience of any potential rewards to treatment facilities.
• Fifth, many nursing homes may have lacked the infrastructure and expertise to engage in quality improvement innovation on their own.
Finally, rather than being incented to change practices because of the possibility of a payout, many facilities saw the demonstration as a reinforcement of actions they were already planning to take or had already begun implementing. Most nursing homes did not change their actions because of the demonstration; rather, some hoped to be rewarded for things that they were already doing or thought their involvement in the demonstration would just be an opportunity to learn from other nursing homes, or prepare for what is to come from CMS moving forward.
Although the NHVBP demonstration was found to have a minimal direct effect on quality, L&M concluded that this result may say more about the specific design features of the demonstration rather than the actual potential of nursing home pay-for-performance.
L&M Recommendation:
If the Medicare program chooses to move forward with the pay-for-performance concept in the nursing home setting, it should consider changes to optimize the response to payment incentives to improve quality. Modifications to the design of any future NHVBP program might include:
• Simplified payment and reward rules;
• Increased payout pools;
• Relaxation/elimination of budget neutrality restrictions such that the likelihood of payout does not hinge on the efforts of other participating facilities;
• Offering more immediate payouts;
• Real time feedback on performance and quality activity results; and providing increased education and guidance on best practices to providers.
Indiana Medicaid Rate Update – VBP, 1/1/14 Rate Letters and the QAF
Medicaid Rates to be Reprocessed with VBP Methodology Starting This Week
As reported in prior newsletters, CMS has approved the Indiana State Plan Amendment to implement the Value Based Purchasing (VBP) methodology effective 7/1/13 (click here for last month’s report). IHCA has been notified by Indiana Medicaid that the 7/1/13 rates will be reprocessed beginning this week in order to implement the rate changes under the VBP methodology. It will take 4 weeks to reprocess the 7/1/13 rates with about 125 facilities per week being processed. Once the 7/1/13 rates are completed, the 10/1/13 rates will be reprocessed next and that will also take 4 weeks.
1/1/14 Rate Letters and the QAF
The State has not yet issued new rate letters for 1/1/14 and will not do so until CMS approves the State Plan Amendment that was submitted to increase the Nursing Facility Medicaid rate by 2%. Recall that Nursing Facility rates were cut by 5% in 2011, and last year after a focused advocacy effort led by the IHCA the Pence Administration started the process to restore 2% of the original 5% cut.
The timing of approval by CMS of the State Plan Amendment is not known at this time as Indiana Medicaid is preparing a response to several CMS requests for additional information. One of those requests focuses on the Indiana Nursing Facility Quality Assessment Fee (QAF).
Indiana Nursing Facility Quality Assessment Fee (QAF)
Under Federal regulations, provider taxes used to generate Federal Medicaid matching funds have to be structured in a very specific way and certain deviations from that process are permitted under a “waiver”. Indiana’s QAF was approved in 2005 under a waiver granted by CMS, and CMS has recently asked Indiana Medicaid for updated data concerning the “B1/B2” compliance test that is required under a waiver for a tax that is not uniformly applied to all nursing facilities, like Indiana’s QAF. The B1/B2 test is a ratio of two separate linear regression analyses where a uniform tax structure is compared with the proposed non-uniform structure. If the B1/B2 ratio is above 1.0, then the tax is approved. Indiana is currently examining the QAF’s B1/B2 ratio and changes, such as the amount of QAF paid, may be necessary to meet the B1/B2 test. IHCA is monitoring this issue closely and will report to membership when more information is available.
As reported in prior newsletters, CMS has approved the Indiana State Plan Amendment to implement the Value Based Purchasing (VBP) methodology effective 7/1/13 (click here for last month’s report). IHCA has been notified by Indiana Medicaid that the 7/1/13 rates will be reprocessed beginning this week in order to implement the rate changes under the VBP methodology. It will take 4 weeks to reprocess the 7/1/13 rates with about 125 facilities per week being processed. Once the 7/1/13 rates are completed, the 10/1/13 rates will be reprocessed next and that will also take 4 weeks.
1/1/14 Rate Letters and the QAF
The State has not yet issued new rate letters for 1/1/14 and will not do so until CMS approves the State Plan Amendment that was submitted to increase the Nursing Facility Medicaid rate by 2%. Recall that Nursing Facility rates were cut by 5% in 2011, and last year after a focused advocacy effort led by the IHCA the Pence Administration started the process to restore 2% of the original 5% cut.
The timing of approval by CMS of the State Plan Amendment is not known at this time as Indiana Medicaid is preparing a response to several CMS requests for additional information. One of those requests focuses on the Indiana Nursing Facility Quality Assessment Fee (QAF).
Indiana Nursing Facility Quality Assessment Fee (QAF)
Under Federal regulations, provider taxes used to generate Federal Medicaid matching funds have to be structured in a very specific way and certain deviations from that process are permitted under a “waiver”. Indiana’s QAF was approved in 2005 under a waiver granted by CMS, and CMS has recently asked Indiana Medicaid for updated data concerning the “B1/B2” compliance test that is required under a waiver for a tax that is not uniformly applied to all nursing facilities, like Indiana’s QAF. The B1/B2 test is a ratio of two separate linear regression analyses where a uniform tax structure is compared with the proposed non-uniform structure. If the B1/B2 ratio is above 1.0, then the tax is approved. Indiana is currently examining the QAF’s B1/B2 ratio and changes, such as the amount of QAF paid, may be necessary to meet the B1/B2 test. IHCA is monitoring this issue closely and will report to membership when more information is available.
2014 Medicaid Eligibility and Spend Down Changes
The Indiana Family and Social Services Administration (FSSA) has announced that effective June 1, 2014 Indiana Medicaid will change the way individuals who are aged, blind or disabled will qualify for Medicaid coverage. The changes will result in a new process that nursing facility residents and nursing facility operators will need to learn and use in order to obtain Medicaid coverage.
On June 1, 2014 Indiana will automatically enroll individuals that the Social Security Administration determines eligible for Supplemental Security Income into Indiana Medicaid and will accept all SSA determinations of disability. This will eliminate the requirement that these applicants also complete a second application and go through a second medical review process to become eligible for Indiana Medicaid with disability coverage. The transition also eliminates the spend down program, which has caused administrative burdens for providers and members, and creates alternative options for those members.
FSSA has established a website with numerous resources for current and future Medicaid recipients, as well as for providers (see http://www.in.gov/fssa/ddrs/4859.htm). Last week, on January 30th, FSSA held an all stakeholders meeting to begin explaining this new process (click here for the presentation). In addition, FSSA has posted a general notice that will go to all current Aged, Blind or Disabled Medicaid members, and FAQs on its website.
A must read for Nursing Facility Residents and Operators
Of critical importance to individuals whose income may exceed the eligibility limit and who want to continue receiving Medicaid, or who want to obtain Medicaid for the first time is the use of a Qualified Income Trust (also known as a Miller Trust). Establishing a QIT allows a recipient, or potential recipient, to place that part of their income that exceeds the income limit into the QIT and have that amount of income disregarded from eligibility determinations. FSSA has released an instructional packet about QITs and how to establish one on its website (click here).
For those residents that exceed the current income standards and are a nursing facility who are on Medicaid, or persons that are receiving home and community based services from Medicaid, a QIT must be established and in use by June 1, 2014 in order for Medicaid eligibility to be continued. In addition to the QIT webpage linked above, FAQs 46 to 55 at http://www.in.gov/fssa/ddrs/4861.htm#Transition_Beneficiaries also discuss the QIT process.
On June 1, 2014 Indiana will automatically enroll individuals that the Social Security Administration determines eligible for Supplemental Security Income into Indiana Medicaid and will accept all SSA determinations of disability. This will eliminate the requirement that these applicants also complete a second application and go through a second medical review process to become eligible for Indiana Medicaid with disability coverage. The transition also eliminates the spend down program, which has caused administrative burdens for providers and members, and creates alternative options for those members.
FSSA has established a website with numerous resources for current and future Medicaid recipients, as well as for providers (see http://www.in.gov/fssa/ddrs/4859.htm). Last week, on January 30th, FSSA held an all stakeholders meeting to begin explaining this new process (click here for the presentation). In addition, FSSA has posted a general notice that will go to all current Aged, Blind or Disabled Medicaid members, and FAQs on its website.
A must read for Nursing Facility Residents and Operators
Of critical importance to individuals whose income may exceed the eligibility limit and who want to continue receiving Medicaid, or who want to obtain Medicaid for the first time is the use of a Qualified Income Trust (also known as a Miller Trust). Establishing a QIT allows a recipient, or potential recipient, to place that part of their income that exceeds the income limit into the QIT and have that amount of income disregarded from eligibility determinations. FSSA has released an instructional packet about QITs and how to establish one on its website (click here).
For those residents that exceed the current income standards and are a nursing facility who are on Medicaid, or persons that are receiving home and community based services from Medicaid, a QIT must be established and in use by June 1, 2014 in order for Medicaid eligibility to be continued. In addition to the QIT webpage linked above, FAQs 46 to 55 at http://www.in.gov/fssa/ddrs/4861.htm#Transition_Beneficiaries also discuss the QIT process.
Independent Informal Dispute Resolution (IIDR) and Informal Dispute Resolution (IDR) – 2013 Data
There were only 2 IIDRs requested in 2013 according to the Indiana State Department of Health (ISDH) and neither process resulted in any change to the original findings. This continues a pattern of low usage of IIDR since the new process was rolled out in January of 2012. It will be interesting to see if IIDR picks up in the coming years due to changes made by CMS in August 2013 that expanded CMS’s escrow authority for all citations in which CMP is imposed. When a CMP is subject to escrow, a facility’s IIDR rights are triggered. Click here for detail on the CMP escrow and IIDR changes from August 2013.
There were 106 survey reports with 215 tags that were processed through the ISDH’s IDR process.
The results are as follows:
Type of IDR Review
• 58% were paper reviews
• 42% were face to face reviews
Scope and Severity of Request Reviews
• 4% were tags with s/s J-L
• 46% were tags with s/s G-I
• 40% were tags with s/s D-F
• 10% were tags with s/s A-C
Review Results
• 66.98% - no changes were made
• 18.14% - resulted in some tags being removed
• 4.65% - resulted in changes to scope and severity
• 1.40% - resulted in examples being removed
• 8.83% - The IDR was withdrawn or had more than one change that is not identified by ISDH databases
There were 106 survey reports with 215 tags that were processed through the ISDH’s IDR process.
The results are as follows:
Type of IDR Review
• 58% were paper reviews
• 42% were face to face reviews
Scope and Severity of Request Reviews
• 4% were tags with s/s J-L
• 46% were tags with s/s G-I
• 40% were tags with s/s D-F
• 10% were tags with s/s A-C
Review Results
• 66.98% - no changes were made
• 18.14% - resulted in some tags being removed
• 4.65% - resulted in changes to scope and severity
• 1.40% - resulted in examples being removed
• 8.83% - The IDR was withdrawn or had more than one change that is not identified by ISDH databases
Residential Care Citation Update
December 2013 Summary
There were 12 Deficiency tags and 2 Offense tags issued in the month of December. Tag 0052 was issued twice for alleged failure to ensure residents are free from abuse, corporal punishment, neglect, or involuntary seclusion. Tag 0241 was issued twice for alleged failure to have medications dispensed only by licensed nursing or by a QMA. Tag 0273 was issued twice for alleged failure to maintain food preparation areas in accordance with state and local sanitation and food handling requirements. Click here for a summary of the December citations.
2013 Most Cited Deficiency and Offense Tags
In 2013, the top ten Deficiency and Offense Tags for residential care facilities were:
There were 12 Deficiency tags and 2 Offense tags issued in the month of December. Tag 0052 was issued twice for alleged failure to ensure residents are free from abuse, corporal punishment, neglect, or involuntary seclusion. Tag 0241 was issued twice for alleged failure to have medications dispensed only by licensed nursing or by a QMA. Tag 0273 was issued twice for alleged failure to maintain food preparation areas in accordance with state and local sanitation and food handling requirements. Click here for a summary of the December citations.
2013 Most Cited Deficiency and Offense Tags
In 2013, the top ten Deficiency and Offense Tags for residential care facilities were:
ISDH IJ/SSQC Update
December 2013 IJ/SSQC
One IJ was issued in December, and that tag was also SSQC. The citation was issued from the alleged failure to initiate CPR for a resident that has a full code status. The resident was found in the lavatory without respirations or pulse, and the LPN that found the resident did not initiate CPR even though she was aware of the resident’s code status. This is the third citation in 2013 for this issue, with all three citations being issued since August 2013. Click here for the December citation.
2013 Summary
The past year saw some of the fewest IJ and SSQC citations in recent memory. For the year there were 17 IJ events and 19 SSQC events in which 36 total tags were cited. By comparison, in 2012 there were 30 IJ events and 28 SSQC events in which 44 total tags were cited, and in 2011 there were 47 IJ events and 50 SSQC events in which 84 total tags were cited.
One IJ was issued in December, and that tag was also SSQC. The citation was issued from the alleged failure to initiate CPR for a resident that has a full code status. The resident was found in the lavatory without respirations or pulse, and the LPN that found the resident did not initiate CPR even though she was aware of the resident’s code status. This is the third citation in 2013 for this issue, with all three citations being issued since August 2013. Click here for the December citation.
2013 Summary
The past year saw some of the fewest IJ and SSQC citations in recent memory. For the year there were 17 IJ events and 19 SSQC events in which 36 total tags were cited. By comparison, in 2012 there were 30 IJ events and 28 SSQC events in which 44 total tags were cited, and in 2011 there were 47 IJ events and 50 SSQC events in which 84 total tags were cited.
The leading citations for 2013 were F225 and F226, with 7 citations each. The primary reason for the citation of F225 was alleged failure to timely report allegations of abuse or failure to thoroughly investigate such allegations. F226, accompanying F225, due to the facility’s policy and procedure requiring timely reporting and thorough investigation. That said, there were a few citations of F225 and F226 for alleged failure to prevent abuse from occurring. The third most cited tag was F323 with 6 citations. Citations of F323 were related to inadequate supervision to protect other residents from sexually inappropriate advances and aggressive resident behaviors, inadequate supervision leading to resident falls, inadequate supervision leading to elopement, and failure to maintain safe water temperatures. The next most cited tag was F309, cited 4 times. One of the citations was issued for alleged failure to ensure medications were administered as ordered by the physician, and three of the citations were issued for alleged failure to initiate CPR for residents that were full code.
To review a summary of all 2013 IJ and SSQC citations, click here.
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