IHCATuesday, August 4, 2015
RUGs IV 48 Grouper
IHCA has received a number of questions about the RUGs IV 48 grouper change that is set to occur on July 1, 2016. Many questions are being generated by the recent release of CMI rosters with the residents converted to the RUGs IV 48, and many facilities are seeing drops in both the all facility and Medicaid only CMIs. In discussions with the State and Myers & Stauffer, the projections given to providers in late 2014 are still on track in that the RUGs IV 48 grouper will add a small amount of reimbursement to the overall system (approx. $6.9M). Projected Medians for the RUGs IV 48 grouper are due to be released by August 31st, and once released payment modeling will be able to be performed more accurately.
ISDH Report Card Score Proposed Changes
IHCA met with the ISDH last month to continue discussions about the proposed changes to the ISDH Report Card Score methodology. After receiving positive and negative feedback, the ISDH is going to revise the proposal by examining the point allocation for each tag cited. Under the original proposal, points were assigned to each tag only with respect to the severity component and did not take into consideration the scope component. In addition, ISDH is ensuring that tags are not double counted when a complaint survey is conducted at the same time an annual survey is conducted. A new data run on the proposed methodology should be available soon, and IHCA will get that out to members asap.
QIO Nursing Home Change Package
The March 2015 v.2.0 Change Packages from the National Nursing Home Quality Care Collaborative released the Change Packages in bite-size strategies and with change bundles to help facilities use the resources available. The National Nursing Home Change Package shares and organizes best practices into seven strategies. Now, you can download each bite-sized strategy of the change package, along with supporting action items, to share with your teams to create measurable change in your facilities. Click here for more information.
Learn More About Proposed Changes to the Requirements of Participation and Submitting Comments to CMS
CMS issued a proposed rule change for the SNF/NF Medicare and Medicaid Requirements for Participation on Monday July 13th 2015. The rule is very large in scope and contains both new requirements and some requirements that have already been issued by CMS via Survey & Certification memoranda. The formatted version of the NPRM proposing changes to the SNF Requirements for Participation is available in the Federal Register, with a deadline for comments submission of 5:00 pm on September 14, 2015.
To provide you with a "Cliff's Notes" version, as well as AHCA comments regarding some of the changes, AHCA has developed a summary of all the proposed changes. Click HERE to view the summary. The actual language in the Requirements for Participation CMS is proposing are contained on pages 42246 to page 42269. Although CMS will review comments on all components of the rule, CMS has requested specific "solicitation for comments" from stakeholders for areas that CMS has not made a specific proposal or recommendation about implementation timelines. These requests appear on pages 10-11 of the summary.
Some of the proposed changes/requirements that stand out:
1. Quality Assurance and Performance Improvement (QAPI) programs;
2. Baseline care plan for each resident within 48 hours of admission;
3. Compliance and ethics programs;
4. Discharge planning;
5. Facility assessment which aims to determine what resources are necessary to care for its residents competently during both day-to-day operations and emergencies; and
6. A more comprehensive Infection Prevention and Control Program including an Infection Prevention and Control Officer.
7. Comments on the use of arbitration agreements.
Given the impact these changes will have on nursing centers, members are encouraged to submit comments themselves to show the importance and concerns raised by CMS. Tips on how to submit comments are below.
Additionally, members are encouraged to send their concerns and any suggested changes to this rule no later than August 6th to Lyn Bentley, so they can be considered for inclusion in AHCA's comments to CMS.
If you send comments directly to Lyn, please copy Zach Cattell at zcattell@ihca.org. You can also submit comments to IHCA to Zach's email as well. IHCA has engaged its Regulatory/Clinical committee and Board of Directors to consider submitting comments in addition to those submitted by AHCA.
Tips to Submit Comments to CMS
* When submitting comments you need to refer to file code CMS-3260-P.
* Organize your comments by major section heading in the proposed rule (see below for list) and then by the outline format used in the rule. For example if you wanted to comment on part of the proposed changes to Resident Rights you would say: "In section Residents Rights (483.10), we have comments about the proposed language in (a) 3. (i.) about "The resident representative has the right to exercise the resident's rights to the extent those rights are delegated to the resident representative."
* Organize each of your comments in into three sections: First site the section of the proposed rule change, followed by your comments/discussion about the rule change, followed by your recommendation or suggested changes to CMS's proposed changes.
* Section of proposed rule (site Federal Registry page number and section headings - see list of section headings below). It is also ok to copy specific language you are commenting on.
* Comments/Discussion
* Recommendations/suggestions
* General comments about the changes in general or that do not contain recommended changes often have little impact on the final rule issued by CMS.
Section Reference of the Proposed Rule
* Resident rights (§483.10)
* Facility responsibilities (§483.11)
* Freedom from abuse, neglect, and exploitation (§483.12)
* Transitions of care (§483.15)
* Resident assessments (§483.20)
* Comprehensive resident-centered care plans (§483.21)
* Quality of care and quality of life (§483.25)
* Physician services (§483.30)
* Nursing services (§483.35)
* Behavioral health services (§483.40)
* Pharmacy services (§483.45)
* Laboratory, radiology, and other diagnostic services (§483.50)
* Dental services (§483.55)
* Food and nutrition services (§483.60)
* Specialized rehabilitative services (§483.65)
* Administration (§483.70)
* Quality assurance and performance improvement (§483.75)
* Infection control (§483.80)
* Compliance and ethics program (§483.85)
* Physical environment (§483.90)
* Training requirements (§483.95)
Where and How to submit your comments:
* When submitting comments you need to refer to file code CMS-3260-P.
* CMS will NOT accept comments by facsimile (FAX) transmission.
* You may submit comments in any one of three ways but only need to use one method (we recommend submitting comments electronically):
1. Electronically. You may submit electronic comments on this regulation to http://www.regulations.gov. Follow the ''Submit a comment'' instructions.
2. By regular mail. You must allow sufficient time for mailed comments to be received before the close of the comment period (NOT postmarked). You can mail written comments to the following address:
3. By express or overnight mail. You must allow sufficient time for mailed comments to be received before the close of the comment period (NOT postmarked). You may send written comments to the following address only:
To provide you with a "Cliff's Notes" version, as well as AHCA comments regarding some of the changes, AHCA has developed a summary of all the proposed changes. Click HERE to view the summary. The actual language in the Requirements for Participation CMS is proposing are contained on pages 42246 to page 42269. Although CMS will review comments on all components of the rule, CMS has requested specific "solicitation for comments" from stakeholders for areas that CMS has not made a specific proposal or recommendation about implementation timelines. These requests appear on pages 10-11 of the summary.
Some of the proposed changes/requirements that stand out:
1. Quality Assurance and Performance Improvement (QAPI) programs;
2. Baseline care plan for each resident within 48 hours of admission;
3. Compliance and ethics programs;
4. Discharge planning;
5. Facility assessment which aims to determine what resources are necessary to care for its residents competently during both day-to-day operations and emergencies; and
6. A more comprehensive Infection Prevention and Control Program including an Infection Prevention and Control Officer.
7. Comments on the use of arbitration agreements.
Given the impact these changes will have on nursing centers, members are encouraged to submit comments themselves to show the importance and concerns raised by CMS. Tips on how to submit comments are below.
Additionally, members are encouraged to send their concerns and any suggested changes to this rule no later than August 6th to Lyn Bentley, so they can be considered for inclusion in AHCA's comments to CMS.
If you send comments directly to Lyn, please copy Zach Cattell at zcattell@ihca.org. You can also submit comments to IHCA to Zach's email as well. IHCA has engaged its Regulatory/Clinical committee and Board of Directors to consider submitting comments in addition to those submitted by AHCA.
Tips to Submit Comments to CMS
* When submitting comments you need to refer to file code CMS-3260-P.
* Organize your comments by major section heading in the proposed rule (see below for list) and then by the outline format used in the rule. For example if you wanted to comment on part of the proposed changes to Resident Rights you would say: "In section Residents Rights (483.10), we have comments about the proposed language in (a) 3. (i.) about "The resident representative has the right to exercise the resident's rights to the extent those rights are delegated to the resident representative."
* Organize each of your comments in into three sections: First site the section of the proposed rule change, followed by your comments/discussion about the rule change, followed by your recommendation or suggested changes to CMS's proposed changes.
* Section of proposed rule (site Federal Registry page number and section headings - see list of section headings below). It is also ok to copy specific language you are commenting on.
* Comments/Discussion
* Recommendations/suggestions
* General comments about the changes in general or that do not contain recommended changes often have little impact on the final rule issued by CMS.
Section Reference of the Proposed Rule
* Resident rights (§483.10)
* Facility responsibilities (§483.11)
* Freedom from abuse, neglect, and exploitation (§483.12)
* Transitions of care (§483.15)
* Resident assessments (§483.20)
* Comprehensive resident-centered care plans (§483.21)
* Quality of care and quality of life (§483.25)
* Physician services (§483.30)
* Nursing services (§483.35)
* Behavioral health services (§483.40)
* Pharmacy services (§483.45)
* Laboratory, radiology, and other diagnostic services (§483.50)
* Dental services (§483.55)
* Food and nutrition services (§483.60)
* Specialized rehabilitative services (§483.65)
* Administration (§483.70)
* Quality assurance and performance improvement (§483.75)
* Infection control (§483.80)
* Compliance and ethics program (§483.85)
* Physical environment (§483.90)
* Training requirements (§483.95)
Where and How to submit your comments:
* When submitting comments you need to refer to file code CMS-3260-P.
* CMS will NOT accept comments by facsimile (FAX) transmission.
* You may submit comments in any one of three ways but only need to use one method (we recommend submitting comments electronically):
1. Electronically. You may submit electronic comments on this regulation to http://www.regulations.gov. Follow the ''Submit a comment'' instructions.
2. By regular mail. You must allow sufficient time for mailed comments to be received before the close of the comment period (NOT postmarked). You can mail written comments to the following address:
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-3260-P
P.O. Box 8010
Baltimore, MD 21244.
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-3260-P
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, MD 21244-1850.
CRE Case Reporting in Marion County
Effective July 1, 2015, all nursing facilities in Marion County will be required to immediately report confirmed or suspected cases of Carbapenem-resistant Enterobacteriaceae (CRE) to the Marion County Public Health Department. The new requirement stems from an amendment to The Health and Hospital Corporation of Marion County code that adds CRE as a reportable communicable disease. Section 7-201 requires any physician or other health care provider who has knowledge of, diagnoses or treats a communicable disease case and every manager of an extended care facility in which there is a communicable disease case to report that case or suspected case to the Marion County Public Health Department. Section 7-202 requires CRE be immediately reported. Laboratories are also required to report evidence of a communicable disease. Failure to properly report could be up to a $1,000 fine, upon conviction. Additionally, The Health and Hospital Corporation of Marion County may seek to abate the public health nuisance or violation of this ordinance in any court of competent jurisdiction. The code can be found at https://www.hhcorp.org/hhc/images/HHCcode/codechapter7.pdf.
Nursing facilities are required to report a case or suspected case of CRE. Consulting with clinicians to learn the signs of CRE and other communicable diseases, as defined in the ordinance, is necessary to properly identify cases. The facility should still report known CRE cases even if the laboratory has already reported them to avoid any possibility of penalty. IHCA expects the Indiana State Department of Health to amend its communicable disease rule later this year to require this same reporting statewide.
Nursing facilities are required to report a case or suspected case of CRE. Consulting with clinicians to learn the signs of CRE and other communicable diseases, as defined in the ordinance, is necessary to properly identify cases. The facility should still report known CRE cases even if the laboratory has already reported them to avoid any possibility of penalty. IHCA expects the Indiana State Department of Health to amend its communicable disease rule later this year to require this same reporting statewide.
Residential Care Citation Update
The ISDH issued 5 Offense Tags and 31 Deficiency Tags to Residential Care Facilities in June. Tag 0273, which involves maintenance of food preparation and service areas in accordance with state and local sanitation standards, was cited five times. Tag 0273 has been cited 40 times so far in 2015. Additionally, Tag 0241, which deals with the administration of medications by licensed nurses or QMAs, was cited 4 times in June, raising the total number of times this citation has been issued in 2015 to 17.
Four citations were issued for Tag 0144 which involves building and grounds maintenance. Tag 0144 has been cited in five of the past six months, with June receiving the highest number of this particular citation since October 2013. One citation for Tag 0217 was issued in June, for a total of 15 citations in 2015. Tag 0217 concerns resident evaluation and services plan.
A citation was issued for Tag 0191 which deals with inadequate kitchen in complying with 410 IAC 7-24 (Sanitary Standards for the Operation of Retail Food Establishments). Tag 0191 has not been cited before.
To review a summary of the June citations, click here.
IJ/SSQC Citation Update
Following IJ citation issued in May, no IJs were cited in June. There was one SSQC citation cited for the month of June. The event involved failing to properly report and implement abuse policy for several allegations. The administrator was not in the building at the time of the incident. The DON was present and followed all proper steps to report the incident but failed to fully report it by sending it to the ISDH. It is important to know who is responsible for filing reports in case the administrator or second in command is not currently there.
Another situation occurred where the administrator filed the abuse allegation, yet failed to alert law enforcement until several days later. There was also a report made by a surveyor who allegedly witnessed an RN become verbally aggressive with a patient when attempting to administer medication. To review a summary of the 2015 IJ/SSQCs and the June 2567, click here.
Another situation occurred where the administrator filed the abuse allegation, yet failed to alert law enforcement until several days later. There was also a report made by a surveyor who allegedly witnessed an RN become verbally aggressive with a patient when attempting to administer medication. To review a summary of the 2015 IJ/SSQCs and the June 2567, click here.
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