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Lets Go! Christine LaRocca, MD April 26, 2019 This material was - PowerPoint PPT Presentation

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Phase 3 of the Nursing Home Final Rule: Lets Go! Christine LaRocca, MD April 26, 2019 This material was prepared by Telligen, the Medicare Quality Innovation Network Quality Improvement Organization, under contract with the Centers for

  1. Phase 3 of the Nursing Home Final Rule: Let’s Go! Christine LaRocca, MD April 26, 2019 This material was prepared by Telligen, the Medicare Quality Innovation Network Quality Improvement Organization, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The contents presented do not necessarily reflect CMS policy. This material is for informational purposes only and does not constitute medical advice; it is not intended to be a substitute for professional medical advice, diagnosis or 1 treatment. 11SOW-QIN-C2-01/18/19-3168

  2. Objectives • The Medicare and Medicaid Programs; Reform of Requirements for Long-Term Care (LTC) Facilities: Why the Revisions? • Broad Overview of Selected Phase 3 Changes This Photo by Unknown Author is licensed under CC BY-SA-NC • Five Elements of Quality Assurance and Performance Improvement (QAPI) and the Medical Director Credits: Dr. David Gifford, Senior Vice President of Quality and Regulatory Affairs at the American Health Care Association (AHCA), generously shared slides and content for this 2 presentation

  3. Medicare and Medicaid Programs; Reform of Requirements for LTC Facilities Why the Revisions? • Significant innovations in resident care and quality assessment practices have emerged • The population of LTC facilities has changed: • More diverse • More clinically complex • Extensive evidence-based research has been conducted and has enhanced knowledge about: • Resident safety • Health outcomes • Individual choice • QAPI https://www.gpo.gov/fdsys/pkg/FR-2016-10-04/pdf/2016-23503.pdf 3 This Photo by Unknown Author is licensed under CC BY-SA-NC

  4. Three Phase Implementation Phase 1 • The first phase of implementation occurred upon the effective date of the final rule • Included those requirements that were unchanged or received minor modification • Specific sections in some regulations • Implemented, practiced and sustained in each nursing home by November 28, 2016 This Photo by Unknown Author is licensed under CC BY-NC-ND 4

  5. • The regulations included in Phase 2 had to be implemented by November 28, 2017 • In addition to those requirements implemented in Phase 1, Phase 2 includes sections of new Phase 2 regulations that require more complex revisions • Time for implementation allowed for changes in survey processes as well as updates to the survey guidance 5

  6. Phase 3 • The regulations included in Phase 3 must be implemented by November 28, 2019 • Includes all the remaining requirements not implemented in Phases 1 and 2 • Final Phase allows for the complete set of revised requirements to be incorporated into the practices of LTC facilities and sufficiently enforced through the updated survey process This Photo by Unknown Author is licensed under CC BY-NC-ND 6

  7. Sections with Changes in the Requirements for Participation (RoP) • • Basis & Scope( § 483.1) Behavioral health services ( § 483.40) • • Definitions ( § 483.5) Pharmacy services ( § 483.45) • • Resident Rights ( § 483.10) Laboratory, radiology, and other diagnostic services ( § 483.50) • Freedom from abuse, neglect, and • exploitation ( § 483.12) Dental services ( § 483.55) • • Food & nutrition services ( § 483.60) Admission, transfer, and discharge rights ( § 483.15) • Specialized rehabilitative services ( § 483.65) • Resident assessment ( § 483.20) • Administration ( § 483.70) • Comprehensive person-centered • Quality assurance and performance care planning ( § 483.21) improvement ( § 483.75) • Quality of life ( § 483.24) • Infection control ( § 483.80) • Quality of care § 483.25) • Compliance and ethics program ( § 483.85) • Physician services ( § 483.30) • Physical environment ( § 483.90) • Nursing services ( § 483.35) • Training requirements ( § 483.95) Red Text = Sections that include Phase 3 7

  8. Broad Overview of Selected Phase 3 Changes (This Isn’t All of Them !) Let’s Talk About: • Infection Preventionist (IP) • Trauma-Informed Care • Comprehensive Training Requirements* • QAPI Program* * Entire section will be implemented in Phase 3 with a few exceptions • This Photo by Unknown Author is licensed under CC BY-ND 8

  9. Infection Preventionist Regulations To Do List § 483.80 (b) Infection preventionist. The • Designate or hire a staff person (e.g. facility must designate one or more nurse or other clinician) who has or will individual(s) as the infection preventionist(s) obtain additional training in infection (IPs) who are responsible for the facility’s control. IPCP. • Opportunity for Training: The IP must: • CDC IP Training • Have primary professional training in https://www.train.org/cdctrain/training nursing, medical technology, microbiology, _plan/3814 epidemiology, or other related field; • Be qualified by education, training, experience or certification; • Work at least part-time at the facility; and • Have completed specialized training in infection prevention and control. 9

  10. CDC Nursing Home Infection Preventionist Training This Nursing Home Infection Preventionist Created by the Centers for Disease Training (new in March 2019) is designed for Control and Prevention (CDC) in individuals responsible for infection IPC collaboration with the Centers for programs in nursing homes. Medicare & Medicaid Services (CMS). • Includes 23 modules that can be The course covers: completed in any order and over • Core activities of effective IPC programs multiple sessions • • Recommended practices to reduce Free continuing medical education (CME), continuing nursing education pathogen transmission, healthcare- (CNE) or continuing education units associated infections and antibiotic (CEUs) available upon course completion resistance • IPC program implementation resources, To learn more: including policy and procedure https://www.telligenqinqio.com/resource/our- templates, audit tools and outbreak work/nursing-home-care/nursing-home-care- investigation tools resources/cdc-nursing-home-infection-preventionist- training/ 10

  11. Infection Preventionist Regulations To Do List § 483.80 (c) IP participation on the • Identify at least one staff Quality Assessment and Assurance person to serve as the IP committee. • Have a back-up person to help • The individual designated as the IP, the IP and also to serve as the or at least one of the individuals if IP if the IP leaves there is more than one IP, must be a ▪ So…get the back -up person member of the facility’s quality trained assessment and assurance committee and report to the committee on the IPCP on a regular basis. 11

  12. Trauma-Informed Care • Appears in Multiple Areas in the Regulations • Requires Providers to be Able to: • Assess for past trauma • Provide care to treat past trauma • Assure staff competency in recognizing and caring for trauma survivors 12

  13. Trauma-Informed Care: Appears in Multiple Areas in the Regulations 42 CFR § 483.25(m) Trauma-informed care. • The facility must ensure that residents who are trauma survivors receive culturally competent, trauma-informed care in accordance with professional standards of practice and accounting for residents’ experiences and preferences in order to eliminate or mitigate triggers that may cause re-traumatization of the resident. 13

  14. Trauma-Informed Care: Appears in Multiple Areas in the Regulations 42 CFR § 483.21(b)(iii) (3) 42 CFR § 483.40 (b) Behavioral Health Comprehensive Care Plans. Services The services provided or arranged by Based on the comprehensive assessment the facility, as outlined by the of a resident, the facility must ensure comprehensive care plan, must — that (ii) Be provided by qualified (1) A resident who displays or is persons in accordance with each diagnosed with mental disorder or resident’s written plan of care. psychosocial adjustment difficulty, or who has a history of trauma and/or (iii) Be culturally-competent and post-traumatic stress disorder, receives trauma – informed. appropriate treatment and services to correct the assessed problem or to attain the highest practicable mental and psychosocial well- being… 14

  15. Comprehensive Person-Centered Care Planning “We do not believe that a definition of trauma-informed care should be added to the definitions section, but note that the interpretative guidelines and the resource noted previously will provide further information regarding culturally-competent and trauma- informed care.” https://store.samhsa.gov/system/files/sma144884.pdf 15

  16. SAMHSA's Concept of Trauma and Guidance for a Trauma-Informed Approach “Individual trauma results from an “A program, organization, or system event, series of events, or set of that is trauma-informed realizes the circumstances experienced by an widespread impact of trauma and individual as physically or understands potential paths for emotionally harmful or life- recovery; recognizes the signs and threatening with lasting adverse symptoms of trauma in clients, effects on the individual’s families, staff, and others involved functioning and mental, physical, with the system; and responds by fully social, emotional, or spiritual well- integrating knowledge about trauma being.” into policies, procedures, and practices, and seeks to actively resist https://www.integration.samhsa.gov/clinic al-practice/trauma re- traumatization.” 16

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