IHCA
On February 12, CMS announced changes to the Five-Star Quality Rating System that will impact how CMS assigns stars for both the Staffing and Quality Measure components, which may impact a skilled nursing center's Overall rating. CMS also will add two new measures to the Quality Measure component: the short-stay antipsychotic measure and the long-stay antipsychotic measure that CMS has been using on Nursing Home Compare for the past several years.
CMS will release to the public these changes on February 20th and will be holding a press briefing on the changes. Based American Health Care Association’s (AHCA) estimates, 165 out of 516 facilities in Indiana will see a decrease of either 1 or 2 stars, 351 facilities will see no change, and 1 facility will pick up one star. These are estimates and may differ from what CMS posts. See below under Resources to access this information.
Following is a summary of the changes to the Five-Star components:
Overall Five-Star rating
No changes to methodology but changes to Staffing and Quality Measure (QM) components will impact your overall rating
Survey component
No changes
Staffing component
Changed how 3- and 4-Star ratings are determined on Staffing component.
Quality Measure component
Added two new Quality Measures to the current nine QMs:
- Short-Stay use of antipsychotics
- Long-Stay use of antipsychotics
Rescaled the Cut Points
For each star level on the Quality Measure component, the cut points were moved. CMS did not provide the new cut points on the call but will release this information in the new technical user's manual. This will result in many members losing one or two stars on the Quality Measure component. Since the QM component contributes to the Overall rating, a sizable number of centers may also lose a star on their Overall rating.
• Resources
AHCA has been working to put together a number of resources on these changes for its members and state associations. AHCA has a dedicated website for this information at www.ahcancal.org/FiveStar. IHCA has taken this information and placed it in our member’s only website as well. Click here to access that information. For either the AHCA or IHCA websites, you will need a member ID and login. The resources are:
• A PowerPoint explaining the Five Star Changes
• Instructions on How to access Five Star Preview Reports
• Sample Letter to Payers Regarding Five Star Changes
• Templates for Communications to Families and Media, as well as general talking points
• Overview of Five Star revisions for the Nation and Indiana
• An Excel spreadsheet of all Indiana NFs with estimated impacts (these impacts are based upon AHCA’s replication of the CMS user guide – actual results may differ once CMS releases the data on Feb. 20th)
IHCA and AHCA will continue to monitor and analyze the changes to the Five Star system and keep you updated.
Thursday, February 19, 2015
Wednesday, February 4, 2015
Indiana Medicaid 5-8 Year Long Term Care Plan
IHCA, HOPE and LeadingAge met with FSSA and OMPP on February 3rd to re-start discussions on the 5-8 year long term care plan that FSSA Secretary John Wernert challenged the industry to help develop. Medicaid Director Joe Moser made it very clear that he is concerned with the imbalance that Indiana has with respect to spending on institutional services versus home and community based services when compared to other states. Though Director Moser has stated to IHCA in the past that a transition to more HCBS does not have to be driven by budgets, Director Moser explained his concern by comparing spending on institutional services versus home HCBS. He presented the following numbers on annual per patient spending:
*Approx. number (AL Waiver only is $14,968, but this does not include other state plan services and needs to before it is a reasonable comparison)
These numbers reflect all that are eligible for NF care and, except for AL Waiver, reflect both waiver and state plan services.
In addition, Director Moser presented data on the percentage spend, and not persons served, on NF and HCBS. The data he presented is below:
Director Moser made it clear that his goal is to change these percentages so that the NF percentage decreases and the HCBS percentage increases. Director Moser also made it clear that he wants the participation of the nursing facility profession to help make this happen, rather than the agency going it alone on a top-down approach. He wishes to develop benchmarks through the planning process, with incentives and penalties, that both the industry and the State will be held to.
The next steps will include the formation of 4 work groups that will feed into the overall planning process. The groups are:
1. Reimbursement – Will examine other state approaches, including managed care (Sec’y Wernert specifically states that managed care needs to be examined and that some in the industry are in favor of managed care)
2. Entry Point – Will examine the ways in which beneficiaries enter the post-acute system and how they are routed to particular services, and then how to change those patterns to ensure right place, right time, least restrictive/costly setting
3. Housing – Will examine challenges to housing for Medicaid beneficiaries
4. Assisted Living – Will examine other state’s approaches to using AL as an alternative to nursing facilities and how Indiana’s structure for waivers and state plan services may need to change to encourage more AL utilization in the Medicaid program
OMPP will put more details together about these workgroups and the overall planning process. IHCA will reach out to members to find members with specific knowledge and time to participate in these work groups.
If you have any questions, please contact Zach Cattell at zcattell@ihca.org or 317-616-9001
Service Type
|
SFY 2014 Spend Per Patient
|
Nursing Facility
|
$48,756
|
AL Waiver
|
$36,000*
|
Home Care
|
$16,950
|
These numbers reflect all that are eligible for NF care and, except for AL Waiver, reflect both waiver and state plan services.
In addition, Director Moser presented data on the percentage spend, and not persons served, on NF and HCBS. The data he presented is below:
SFY 2014
|
SFY 2013
|
SFY 2012
|
SFY 2011
|
SFY 2010
|
|||||
NF Spend
|
HCBS Spend
|
NF Spend
|
HCBS Spend
|
NF Spend
|
HCBS Spend
|
NF Spend
|
HCBS Spend
|
NF Spend
|
HCBS Spend
|
75.4%
|
24.6%
|
78.4%
|
21.6%
|
78.6%
|
21.4%
|
79.1%
|
20.9%
|
79%
|
21%
|
Director Moser made it clear that his goal is to change these percentages so that the NF percentage decreases and the HCBS percentage increases. Director Moser also made it clear that he wants the participation of the nursing facility profession to help make this happen, rather than the agency going it alone on a top-down approach. He wishes to develop benchmarks through the planning process, with incentives and penalties, that both the industry and the State will be held to.
The next steps will include the formation of 4 work groups that will feed into the overall planning process. The groups are:
1. Reimbursement – Will examine other state approaches, including managed care (Sec’y Wernert specifically states that managed care needs to be examined and that some in the industry are in favor of managed care)
2. Entry Point – Will examine the ways in which beneficiaries enter the post-acute system and how they are routed to particular services, and then how to change those patterns to ensure right place, right time, least restrictive/costly setting
3. Housing – Will examine challenges to housing for Medicaid beneficiaries
4. Assisted Living – Will examine other state’s approaches to using AL as an alternative to nursing facilities and how Indiana’s structure for waivers and state plan services may need to change to encourage more AL utilization in the Medicaid program
OMPP will put more details together about these workgroups and the overall planning process. IHCA will reach out to members to find members with specific knowledge and time to participate in these work groups.
If you have any questions, please contact Zach Cattell at zcattell@ihca.org or 317-616-9001
Indiana Medicaid RUGs IV Update
IHCA, HOPE and LeadingAge met with representatives from FSSA and Indiana Medicaid (OMPP) on February 3rd to discuss the proposed transition to RUGs IV. OMPP continues to push for RUGs IV 66 grouper to be implemented on July 1, 2016. Two weeks ago OMPP made a new proposal, which was to move to RUGs IV 66 grouper, to increase the Special Care Unit add-on in 2016 by $17M and then eliminated the add-on in the following year, and to increase the QAF. Per the direction of the IHCA Payment/Reimbursement Committee and IHCA Board, IHCA staff rejected that proposal. IHCA is working with HOPE and LeadingAge to develop a unified proposal to present to OMPP in the coming week or so.
If you have any questions, please contact Zach Cattell at zcattell@ihca.org or 317-616-9001.
If you have any questions, please contact Zach Cattell at zcattell@ihca.org or 317-616-9001.
CMS Resumes Part B Therapy Manual Medical Review (MMR) Program
Late last week, the Centers for Medicare and Medicare Services (CMS) sent a notice and a FAQ document to organizations representing providers that they were resuming the Medicare Part B therapy manual medical review (MMR) program immediately. As you may recall, the MMR program was implemented by CMS in October 2012 as part of a previous extension of the therapy caps exceptions process. Under MMR, Medicare recovery audit contractors (RACs) are to review Part B therapy claims over a $3700 threshold per beneficiary per year. Due to problems in the MMR process and delays in issuing new RAC contracts, the therapy MMR program was put on a 'pause' at the end of February 2014.
Below is a summary of the key elements of the MMR resumption that AHCA members and their clinical and billing staff should be aware of and prepare for:
1. Starting immediately, RACs may resume part B therapy MMR for all MMR eligible claims over the $3700 threshold for claims paid between March 1, 2014 and December 31, 2014.
2. The reviews will be post-pay review only in all states for the 2014 claim reviews.
3. Claims will be reviewed in chronological order so that, for example, claims paid in March 2014 will be reviewed before claims paid in April 2014.
4. There will be 5 waves of reviews conducted to address all 2014 MMR reviews which AHCA estimates will be conducted from February through August 2015. Providers with therapy MMR eligible claims should expect to receive therapy MMR additional development requests (ADRs) approximately every 45 days as follows:
• Phase 1 - One claim review request will be issued in the ADR.
• Phase 2 - Up to 10 percent of the total MMR eligible claims for 3/14-12/14 will be included in the ADR.
• Phase 3 - Up to 25 percent of the remaining MMR eligible claims for 3/14-12/14.
• Phase 4 - Up to 50 percent of the remaining MMR eligible claims for 3/14-12/14.
• Phase 5 - Up to 100 percent of the remaining MMR eligible claims for 3/14-12/14
CMS notes that this current resumption only applies to facility-based providers, including skilled nursing facilities. In addition, CMS has not identified a process yet for how they intend to conduct reviews for 2015 MMR eligible claims. While CMS state they do not plan to post additional information regarding these reviews, AHCA will continue to seek further clarification.
AHCA has been, and continues to be very concerned with the serious flaws in the arbitrary $3700 therapy MMR threshold that Congress established, and how CMS has interpreted to mean that 100 percent of claims above this threshold must receive burdensome complex review, regardless of beneficiary condition, or provider history of compliance with Medicare policy.
AHCA is actively engaged with Congress in advocating for therapy reforms like the therapy cap repeal provisions reported out by the Senate Finance Committee in the 113th Congress. However, since that may take some time, we are also seeking immediate reforms to the therapy MMR program as a bridge to the larger reforms, and are asking Congress to require CMS to target MMR reviews and education efforts to providers with a history of improper payments rather than the cumbersome 100 percent review process described above.
If you have any questions please feel free to contact Danie Ciolek, Senior Director, Therapy Advocacy, at dciolek@ahca.org or 302-740-7888.
Below is a summary of the key elements of the MMR resumption that AHCA members and their clinical and billing staff should be aware of and prepare for:
1. Starting immediately, RACs may resume part B therapy MMR for all MMR eligible claims over the $3700 threshold for claims paid between March 1, 2014 and December 31, 2014.
2. The reviews will be post-pay review only in all states for the 2014 claim reviews.
3. Claims will be reviewed in chronological order so that, for example, claims paid in March 2014 will be reviewed before claims paid in April 2014.
4. There will be 5 waves of reviews conducted to address all 2014 MMR reviews which AHCA estimates will be conducted from February through August 2015. Providers with therapy MMR eligible claims should expect to receive therapy MMR additional development requests (ADRs) approximately every 45 days as follows:
• Phase 1 - One claim review request will be issued in the ADR.
• Phase 2 - Up to 10 percent of the total MMR eligible claims for 3/14-12/14 will be included in the ADR.
• Phase 3 - Up to 25 percent of the remaining MMR eligible claims for 3/14-12/14.
• Phase 4 - Up to 50 percent of the remaining MMR eligible claims for 3/14-12/14.
• Phase 5 - Up to 100 percent of the remaining MMR eligible claims for 3/14-12/14
CMS notes that this current resumption only applies to facility-based providers, including skilled nursing facilities. In addition, CMS has not identified a process yet for how they intend to conduct reviews for 2015 MMR eligible claims. While CMS state they do not plan to post additional information regarding these reviews, AHCA will continue to seek further clarification.
AHCA has been, and continues to be very concerned with the serious flaws in the arbitrary $3700 therapy MMR threshold that Congress established, and how CMS has interpreted to mean that 100 percent of claims above this threshold must receive burdensome complex review, regardless of beneficiary condition, or provider history of compliance with Medicare policy.
AHCA is actively engaged with Congress in advocating for therapy reforms like the therapy cap repeal provisions reported out by the Senate Finance Committee in the 113th Congress. However, since that may take some time, we are also seeking immediate reforms to the therapy MMR program as a bridge to the larger reforms, and are asking Congress to require CMS to target MMR reviews and education efforts to providers with a history of improper payments rather than the cumbersome 100 percent review process described above.
If you have any questions please feel free to contact Danie Ciolek, Senior Director, Therapy Advocacy, at dciolek@ahca.org or 302-740-7888.
Tuesday, February 3, 2015
CMS Issues Clarification Requiring In-Person CPR Training of Facility Staff
On Friday Jan. 23, 2015, CMS sent to AHCA updated guidance at F-155 - Rights Regarding Refusal of Treatment and Participation in Experimental Research and Advance Directives. The memo and revised operations manual has not yet been posted to the CMS website, but can be accessed by clicking here.
The updated guidance makes changes related to one area: CPR Certification. According to the
memo summary:
CPR Certification - Staff must maintain current CPR certification for healthcare providers through CPR training that includes hands-on practice and in-person skills assessment. Online-only certification is not acceptable.
The content of the memo provides additional detail about the certification.
The updated guidance makes changes related to one area: CPR Certification. According to the
memo summary:
CPR Certification - Staff must maintain current CPR certification for healthcare providers through CPR training that includes hands-on practice and in-person skills assessment. Online-only certification is not acceptable.
The content of the memo provides additional detail about the certification.
AHCA Summary of Key Provisions in President's Proposed FY2016 Budget
On Monday, AHCA released the follow summary of President Obama's Fiscal Year 2016 Budget:
Today the President released his FY2016 budget proposal. There’s no question that a president’s budget wields considerable influence on how our government sets and defines its priorities, as well as to what Congress should subsequently pay attention. However, any changes must be implemented through the legislative process by Congress.
As it regards our profession, this budget looks similar in many ways to past years. As was true for last year’s budget, the Administration did not include cuts to provider taxes. We applaud President Obama for his continued efforts to protect Medicaid for the hundreds of thousands of our residents who rely on the program for their care.
When it comes to Medicare, however, the budget’s proposed cuts are ill advised. This year’s budget does propose significant cuts to Medicare, including reducing the market basket, cutting bad debt reimbursement and more. We will continue to strongly oppose the arbitrary, deep Medicare cuts suggested in this budget. The proposed cuts are particularly outrageous given the recent reports from MedPAC that our centers operate on a thin 1.9% margin. AHCA/NCAL will continue to oppose these arbitrary, deep cuts, and we don’t expect them to become law. In the past, our profession has worked with the White House and Congress to offer better ways of finding Medicare savings, and we will continue to do so.
Below is a short summary of the budget provisions in the President’s FY2016 budget that have direct impact on our profession.
Medicare
Post-acute care market basket cuts
• The budget reduces the home health, IRF and LTCH market basket update by 1.1% each year 2016 through 2025, with the floor set at a rate freeze. The budget reduces market basket updates for all PAC providers, but accelerates SNF cuts beginning with a -2.5% update in FY2016 and a reduction to -0.97% in FY2023. This is projected to save $102.1 billion from 2016-2025.
Reduce Medicare coverage of bad debts
• The President proposes reducing bad debt payments from 65% to 25% for all eligible providers over three years beginning in 2016. This proposal will save approximately $31.1 billion from 2016-2025. This proposal was included in the President’s FY2015 budget.
Implement bundled post-acute care payment
• Beginning in 2020, at least half of the payments for LTCHs, IRFs, SNFs and home health services would be bundled. Payments would be bundled for at least half of the total payments for post-acute care providers. A permanent and total cumulative 2.85% cut would be applied by 2022. This proposal is projected to save $9.3 billion from 2016-2025.
Implement value-based purchasing for PAC providers
• While it is budget neutral, it is important to note that the President’s Budget implements a value-based purchasing program for several additional provider types, including home health, SNFs, ambulatory surgical centers and hospital outpatient departments beginning in 2017. At least 2% of payments must be tied to the quality and efficiency of care in the first two years of implementation, and at least 5% beginning in 2019. This proposal has no budget impact.
Strengthen the Independent Payment Advisory Board
• The budget requires IPAB cuts to take effect when Medicare spending growth exceeds Gross Domestic Product (GDP) +.5%. Current law is GDP +1%. This is estimated to save $20.9 billion from 2016-2025.
Encourage appropriate use of inpatient rehabilitation facilities
• The President proposes adjusting the standard for classifying a facility as an inpatient rehabilitation facility (IRF) by requiring that at least 75% of patient cases admitted to an IRF meet one or more of 13 designated severity conditions beginning in 2016. The current standard is set at 60%. This proposal is projected to save $2.2 billion from 2016-2025.
Medicaid
Provider Assessments not cut in the President’s Budget:
• As was the case last year, the President’s budget does not propose reducing or eliminating the provider assessments. Since Congress is likely to consider such cuts as an area to save money, it is a positive that the President did not include it in his recent budget.
Structural changes for delivery of long term services and supports:
• The budget includes a number of proposed changes that would promote the use of home and community based services. These proposals were not included in last year’s budget. It is important to note that even if these options were to be passed into law, states would have to choose to include them in their Medicaid program.
Other
Strengthening program integrity
• The budget includes new investments in program integrity totaling $201 million in FY2016 and $4.6 billion over ten years. These investments include continuing to fund the full Health Care Fraud and Abuse Control discretionary cap adjustment, increasing mandatory Medicaid Integrity Program funding, and providing more funding to recovery auditors to undertake more corrective actions that will help reduce improper payments. In total program integrity investments would yield an estimated $21.7 billion in savings to Medicare and Medicaid over ten years.
As always, AHCA/NCAL will continue to provide you all the latest information on the President’s budget proposal, as well as other developments on Capitol Hill. If you’d like to read more about the President’s budget, you can view it online at http://www.whitehouse.gov/omb/budget/Overview.
If you have specific questions for AHCA/NCAL, please contact Government Affairs at 202.898.2816.
Today the President released his FY2016 budget proposal. There’s no question that a president’s budget wields considerable influence on how our government sets and defines its priorities, as well as to what Congress should subsequently pay attention. However, any changes must be implemented through the legislative process by Congress.
As it regards our profession, this budget looks similar in many ways to past years. As was true for last year’s budget, the Administration did not include cuts to provider taxes. We applaud President Obama for his continued efforts to protect Medicaid for the hundreds of thousands of our residents who rely on the program for their care.
When it comes to Medicare, however, the budget’s proposed cuts are ill advised. This year’s budget does propose significant cuts to Medicare, including reducing the market basket, cutting bad debt reimbursement and more. We will continue to strongly oppose the arbitrary, deep Medicare cuts suggested in this budget. The proposed cuts are particularly outrageous given the recent reports from MedPAC that our centers operate on a thin 1.9% margin. AHCA/NCAL will continue to oppose these arbitrary, deep cuts, and we don’t expect them to become law. In the past, our profession has worked with the White House and Congress to offer better ways of finding Medicare savings, and we will continue to do so.
Below is a short summary of the budget provisions in the President’s FY2016 budget that have direct impact on our profession.
Medicare
Post-acute care market basket cuts
• The budget reduces the home health, IRF and LTCH market basket update by 1.1% each year 2016 through 2025, with the floor set at a rate freeze. The budget reduces market basket updates for all PAC providers, but accelerates SNF cuts beginning with a -2.5% update in FY2016 and a reduction to -0.97% in FY2023. This is projected to save $102.1 billion from 2016-2025.
Reduce Medicare coverage of bad debts
• The President proposes reducing bad debt payments from 65% to 25% for all eligible providers over three years beginning in 2016. This proposal will save approximately $31.1 billion from 2016-2025. This proposal was included in the President’s FY2015 budget.
Implement bundled post-acute care payment
• Beginning in 2020, at least half of the payments for LTCHs, IRFs, SNFs and home health services would be bundled. Payments would be bundled for at least half of the total payments for post-acute care providers. A permanent and total cumulative 2.85% cut would be applied by 2022. This proposal is projected to save $9.3 billion from 2016-2025.
Implement value-based purchasing for PAC providers
• While it is budget neutral, it is important to note that the President’s Budget implements a value-based purchasing program for several additional provider types, including home health, SNFs, ambulatory surgical centers and hospital outpatient departments beginning in 2017. At least 2% of payments must be tied to the quality and efficiency of care in the first two years of implementation, and at least 5% beginning in 2019. This proposal has no budget impact.
Strengthen the Independent Payment Advisory Board
• The budget requires IPAB cuts to take effect when Medicare spending growth exceeds Gross Domestic Product (GDP) +.5%. Current law is GDP +1%. This is estimated to save $20.9 billion from 2016-2025.
Encourage appropriate use of inpatient rehabilitation facilities
• The President proposes adjusting the standard for classifying a facility as an inpatient rehabilitation facility (IRF) by requiring that at least 75% of patient cases admitted to an IRF meet one or more of 13 designated severity conditions beginning in 2016. The current standard is set at 60%. This proposal is projected to save $2.2 billion from 2016-2025.
Medicaid
Provider Assessments not cut in the President’s Budget:
• As was the case last year, the President’s budget does not propose reducing or eliminating the provider assessments. Since Congress is likely to consider such cuts as an area to save money, it is a positive that the President did not include it in his recent budget.
Structural changes for delivery of long term services and supports:
• The budget includes a number of proposed changes that would promote the use of home and community based services. These proposals were not included in last year’s budget. It is important to note that even if these options were to be passed into law, states would have to choose to include them in their Medicaid program.
Other
Strengthening program integrity
• The budget includes new investments in program integrity totaling $201 million in FY2016 and $4.6 billion over ten years. These investments include continuing to fund the full Health Care Fraud and Abuse Control discretionary cap adjustment, increasing mandatory Medicaid Integrity Program funding, and providing more funding to recovery auditors to undertake more corrective actions that will help reduce improper payments. In total program integrity investments would yield an estimated $21.7 billion in savings to Medicare and Medicaid over ten years.
As always, AHCA/NCAL will continue to provide you all the latest information on the President’s budget proposal, as well as other developments on Capitol Hill. If you’d like to read more about the President’s budget, you can view it online at http://www.whitehouse.gov/omb/budget/Overview.
If you have specific questions for AHCA/NCAL, please contact Government Affairs at 202.898.2816.
Residential Care Facility Citation Update
The December 2014 Offense and Deficiency citations followed a familiar pattern with Tag 273 being cited 6 times in the month. The failure to maintain food preparation and services areas in accordance with state and local sanitation and safe food handling standards is the leading tag for residential care facilities in 2014 (as it was in 2013). Next, Tag 217 was cited 5 times, the second highest amount for any month in 2014 for this tag. Failure to use appropriately trained staff for resident evaluation, and review of the plan with the resident signing off on any changes to the plan is ws the 3rd leading tag in 2014. Next, Tag 241 was cited 3 times in December for failure to have the medication(s) ordered by the resident’s physician administered by licensed nursing personnel or QMAs. Tag 241 was the 2nd most cited in 2014. Lastly, Tag 414 was cited 3 times in December for failure to ensure that staff washed their hands after each direct resident contact for which professional practice indicates that hand washing is appropriate. Tag 414 was 6th on the list of most frequent in 2014. Below is a chart of the top ten Offense and Deficiency citations in Residential Care Facilities in 2014.
To review a summary of all of the December Offense and Deficiency citations, click here.
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To review a summary of all of the December Offense and Deficiency citations, click here.
ISDH IJ/SSQC Citation – 2014 Year in Review
This year there were 23 IJ events and 24 SSQC events in which 47 total tags were cited. This is a bit higher than in 2013, which saw historic lows for IJs and SSQCs. However, 2014 was still a positive when compared to 2011 and prior years. Since 2011, IJ and SSQC citations have been falling, relative to prior years.
.jpg)
The leading citations for 2014 were F225 and F226, with 10 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.
The third most cited tag was F323 with 7 citations
• Citations of F323 were related to inadequate supervision inadequate supervision leading to elopement, to protect other residents from sexually inappropriate advances and aggressive resident behaviors, inadequate supervision leading to choking and death
• No IJs cited under F323 for falls or for hot water temps!
The fourth most cited tag was F223, cited 5 times
• All were issued during or before August
• Cited twice in 2013, once in 2012, and 4 times in 2011
• Citations related to verbal and physical abuse from staff to residents, failure to prevent physical and verbal abuse between residents, prevention of sexual abuse
Below is a chart of all 2014 IJ and SSQC citations, listed in order of frequency.
.jpg)
The leading citations for 2014 were F225 and F226, with 10 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.
The third most cited tag was F323 with 7 citations
• Citations of F323 were related to inadequate supervision inadequate supervision leading to elopement, to protect other residents from sexually inappropriate advances and aggressive resident behaviors, inadequate supervision leading to choking and death
• No IJs cited under F323 for falls or for hot water temps!
The fourth most cited tag was F223, cited 5 times
• All were issued during or before August
• Cited twice in 2013, once in 2012, and 4 times in 2011
• Citations related to verbal and physical abuse from staff to residents, failure to prevent physical and verbal abuse between residents, prevention of sexual abuse
Below is a chart of all 2014 IJ and SSQC citations, listed in order of frequency.
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