Idaho Department of Health and Welfare Study Haffenreffer and Associates, Inc. Demi Haffenreffer, President / CEO www.consultdemi.net demi@consultdemi.net
Our Journey today Introduction Findings / Recommendations Closing
Scope of Study Compare three States to Idaho to: Identify survey inconsistencies Study the organizational culture of the Division to: Search for data correlations that may lead to increase turnover and vacant positions Are Idaho citizens getting good care? Provide recommendations
Design of Study Surveys IDR s Casper data CMS data Interviews Nursing Home Compare My 40 years working in the field
Findings On the Provider Side
Top Five Tags (from Casper Data) Idaho Alaska Wyoming Montana F280 F241 F371/441 F281 F309 F371 309 F323 F323/F329 F323/441 323/312 F441 F441 F329 F253 F279 F314 6 tags tied F282 F514
F309 Systems and Processes What does F309 address? What are the necessary components for a surveyor to state a decline in status was avoidable vs. unavoidable? What are the components of a good pain management system? Do your staff know how to differentiate between a pressure ulcer and a skin issue that is non-pressure related and how is this documented? What processes have you put into place r/t dialysis & end of life care? Have you used the interpretive guidance and checklist for staff training for Dementia Care?
F309 - CHANGES IN RESIDENT CONDITIONS / DECLINES Use the survey criteria for avoidable vs. unavoidable F309 says it all! The foundation of quality of care Assessment of risk and needs; implementation; monitoring; evaluation Observation & reporting (24-hr. report) Good evaluation & assessment techniques see next slide Documentation & ongoing monitoring Notification of family & physicians Further assessment of at risk areas for decline related to current condition change Care planning (temporary & ongoing) Going electronic throwing the baby out with the bath water
What is a Comprehensive Assessment? A written assessment that tells us the so what about the real or potential problem and the rationale for care planning or not. What does the process include? Gathering essential data Defining the problem Cause and effect analysis Identifying goals & objectives of care Discussion with resident / family & selecting appropriate interventions F280 - Care Planning Monitoring of the Care Plan Interventions Evaluating the effectiveness of the care plan interventions and updating as needed A quick chat about Learning Horizons
LEARNING HORIZONS
F309 Components of a Good Pain Management System Recognition Training in current standards for treatment Assessment regardless of CAA triggers Using the CAA as a guideline in assessing Monitoring Frequency Evaluation Frequency Build an institutional commitment to pain management in collaboration with the resident
F314 Systems and Processes Thorough examination of skin 2-6 hours after admission Assessment of risk with implementation of interventions in keeping with identified risk Weekly skin checks Daily and weekly documentation of current wounds with consideration of change in treatment when wound not progressing towards healing Clear physician orders Monthly QAPI analysis Specific consistent processes when wound found See assessment slide RD consults Training and competency checks
F323 Systems and Processes What does this tag address? An institutional commitment to resident safety without sacrificing resident autonomy. Assessment of risks Resident Specific Environment Specific Identifying goals Resident Specific Environment Specific Implementing actions Resident Specific Environment Specific Monitoring Evaluating
F329 Systems and Processes Behavior / intervention tracking & root-cause analysis Proactive & aggressive interventions to prevent resident to resident behaviors Assessment using CAA s 8 (Mood), 9 (Behavior),17 (Drugs) & F329 Investigative Protocol Interdisciplinary (social services and activities) Rule out pain & depression as cause for behaviors Attempt medications other than Antipsychotics GDR s Make a QAPI goal to reduce Antipsychotic use Assist your pharmacist with drug reviews by providing specific resident information Develop documented goals for medications
F441 Systems and Processes Continuous and aggressive monitoring daily closely aligned with changes of condition and that system Don t wait to an outbreak is obvious before taking aggressive action It is more than just tracking info on a log It is cross referencing labs, bugs, meds (antibiotic surveillance) and employee illnesses It is trending and analyzing It is conducting outcome and process auditing Staff training is key Competency testing is key
Implementing Plans of Correction
My Findings and Some Advice Focusing only on the tag examples as opposed to the whole tags Be thorough in your approach Review those records of the resident most likely affected and you know will be chosen Monitor your plan The surveyor placing you back into compliance does not mean you fixed the problem effectively or efficiently
Informal Dispute Resolution
My Findings and Some Advice 50% changed in Idaho IDR write up not congruent with the point of the citation Get organized Some general principles
General Principles No disputes just for the sake of arguing Informal dispute is not a place to air concerns about the survey or surveyors Decide if a phone call & sending further documentation can clear up the matter Scope/severity cannot be disputed unless you have a substandard citation however inaccuracies corrected can lead to a lower scope/severity You must still answer with a plan of correction however I add that we are disputing the citation
Evaluating citations for dispute Inaccurate facts in the citation in one or more examples Incomplete facts in the citation examples that could change a scope/severity or the general point of the citation The survey examples do not fit with the regulatory language or surveyor guidance Over-stated facts of the citation Facts do not list specifics & call to question the validity of the citation
Keys to Success A well stated position Clinical record back-up or other evidence to support your position Well organized documentation with well labeled attachments A good attitude show respect but no need to grovel A good presentation at the actual dispute
Some Additional Info
ARE THE CITIZENS OF IDAHO RECEIVING QUALITY CARE?
How Do I Know? Some things to Consider Quality Measures as Compared to the Nation and the three QIS States Pressure Ulcers Accidents Antipsychotic medication use 50% of facilities with an overall rating of 2 stars have 4 stars in quality measures Something else to consider from QM s RN Staffing Acknowledge the progress the Division has made
Bureau Findings
Vacancies / Turnover Increased Surveyor Workload Hiring Practices Increased number of Revisits Increased number of G citations