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UNITED VOICES PROVIDER & OSDH ADDRESS COMPLIANCE QUESTIONS JOYCE CLARK CEO of Achievis Senior Living Associates Developed 7 Assisted Living & Memory Care Communities in Oklahoma Management, Marketing, & Development


  1. UNITED VOICES PROVIDER & OSDH ADDRESS COMPLIANCE QUESTIONS

  2. JOYCE CLARK  CEO of Achievis Senior Living Associates  Developed 7 Assisted Living & Memory Care Communities in Oklahoma  Management, Marketing, & Development  Ranging from Mock Surveys & Interim Management to Turn-Key New Build

  3. MARY FLEMING  Director of Survey at Oklahoma State Department of Health  25 Years of Experience  Bachelors in Nursing Science. Masters in Human Resources Management.  Project Officer for Development of AL Rules & Survey Protocol.

  4. LET’S START WITH MOST FREQUENT CITATIONS…

  5. MISSING ITEMS IN RESIDENT CONTRACT  Licensure acceptance does not necessarily mean all required items are in contract.  Modifications change original contract compliance & need OSDH approval.

  6. SUGGEST THESE ITEMS  310:663-13-2 BE BOLD OR  Center Name & Address UNDERLINED  Admission Criteria  Services Provided  Discharge Criteria  Dispute Resolution & Grievance Procedures  Charges for Services  Agreement Includes Marketing Materials & Regulations  Term, Renewal, & Cancellation  Conformity with State Law  Provision for 5 Day Transfer

  7. MISSING “I” OR “P”  PIG method not followed.  Person preparing dose does not GIVE it. Leaves in apt. or on table for resident to take later.  Forgot to initial.

  8. OUT OF STOCK MEDICATIONS  Especially crucial if for prevention of seizures or for severe infection.  Failure to follow physician orders.  Suggest fee to provide emergency back- up meds plus cost. Fee terms must be in contract.

  9. ASSESSMENTS  Not Signed / Coordinated by RN in Timely Manner.  Documentation of Personal Interview Between Resident or Resident’s Representative & Person Completing Form.  Appropriate Assessment Was Not Performed.

  10.  Braden Scale COMPLETE APPROPRIATE  Mini-Mental ASSESSMENT TO DETERMINE  Fall Risk IF RESIDENT HAS NURSING  AIMS NEEDS. EXAMPLES:  Admission Criteria Verification  Evacuation Capability  Comprehensive Evaluation of Needs and Preferences (2 years)  Pain  Elopement Risk  Skin Evaluation  Medication Review  Self-Medication Assessment  Quarterly RN Wellness Reviews – Not Required But Helpful Process

  11. USE ASSESSMENT(S) TO DEVELOP SERVICE PLAN  Address resident need staff is to accommodate.  Once potential problem / need is known, comprehensive care plan should have preventive measures outlined.  Clinical Nursing Skills is good guideline.  What do you do if resident has pressure ulcer? If sits or lays a lot?

  12. “SPECIFIC INTERVENTIONS ON RESIDENT’S CARE PLAN TO PROMOTE HEALING & PREVENT DEVELOPMENT OF POTENTIAL PRESSURE SORES”  Skin assessments for prevention of re-occurring redness and/or sores to the buttocks and skin.  Use and maintenance of pressure relieving devices.  Institution and DOCUMENTATION of a position change schedule q 2 hours to avoid prolonged pressure in one area.  Implementation of measures for the protection of the resident’s skin from excess moisture to prevent maceration.  Evaluation and possible institution of 2000 – 3000 calories / day of fluid to provide calories, protein, and fluids necessary for fluid repair.  Instructions related to interventions for direct care staff for the promotion and prevention of actual and potential pressure sores / skin breakdown.

  13. OTHER CARE PLAN TIPS  Pain Interventions Such as ROM, Exercise, Heat, Cold, Topical Ointments, Repositioning.  Address Most Prevalent Needs.  Update Plan As Needs Change.  Create 1-Page Template Need Plans. Easy to Use for Inservices. Individualize for Resident Updates / Temporary Services.

  14. RISK MANAGEMENT DEFICIENCIES  “Right to Fall.” Residents have “right to safety” and fall prevention measures must be taken.  “Right to Drive.”

  15. INCIDENT TIMELINE  If on Friday or weekend, the report (ODH 283) does not get sent within 1 business day of discovery.  ODH Form 718 - Notification of Nurse Aide Abuse, Neglect, Mistreatment or Misappropriation of Property (1 business day of identifying alleged perpetrator).

  16. NURSE AIDE REGISTRY SKILLS PERFORMANCE CHECKLIST INDICATES AIDES CAN NOT DO:  Change colostomy bags?? Factors like RN staffing for scheduled assessments may make this a delegable task. To be discussed more.  Perform neuro checks  Injury assessment or wound care  Picc line  Setting O2 flow

  17. ON THE OTHER HAND… SKILLS ON CHECKLIST  Perform Active and Passive Range of Motion Exercises  Provide Indwelling Catheter Care

  18. LET’S ANSWER ADMINISTRATOR QUESTIONS…

  19. RECENT DEFICIENCIES CITE “PLAN OF CARE DID NOT CONTAIN NURSING INTERVENTIONS WITH MEASURABLE GOALS AND OUTCOMES ”. WHAT REGULATION OR LAW SAYS ASSISTED LIVING SERVICE PLANS MUST HAVE “MEASURABLE GOALS AND OUTCOMES”?  This language was intended to clarify care plan contents.

  20. IF DOCTOR WRITES A MED ORDER THAT WE KNOW RESIDENT WON’T TAKE, DO WE HAVE TO FILL IT?  YES. Must give (offer) medications as ordered.  Have doctor clarify the order.

  21. HOW DO I REPORT A HOME HEALTH COMPANY THAT IS NOT ABIDING  Policy. Third party contract. REGULATIONS?  Admission criteria & assessment determines scope of services.  Contact attending doctor & ask for change. Remind of fraud liability.  OSDH Home Health Complaint Hotline.  Send 3 complaints to OSDH LTC.  Copy director of HH & resident’s physician.  Involve Attorney General & Oklahoma Health Care Authority.

  22. HOW CAN WE OFFER RESIDENT CHOICE WHILE ALSO EFFECTIVELY COORDINATING THIRD PARTY CARE? CAN WE LIMIT HOME HEALTH / HOSPICE CHOICE TO SHORT LIST OF PROVIDERS WHO MEET FACILITY STANDARDS?  Admission policy refers to recommended list of providers.  Disclose prior to admission

  23. IS A CNA QUALIFIED TO PUT TED HOSE ON A RESIDENT?  YES  Oklahoma Nurse Aide Registry Skills Performance Checklist.  Applying Compression Support Stockings is Part of Training / Orientation.

  24. DO DIETARY SUPPLEMENTS NEED TO BE DOCUMENTED?  YES if supplement is administered as if was a medication / on a schedule.  YES if part of care plan from dietician or licensed professional.  Document on TAR.

  25. WHEN ARE ADL’S REQUIRED TO BE CHARTED?  ADL charting is not required. Per facility policy.  Chart when care is performed or delegated by licensed professional.  Meal / fluid intake if ordered.  Range of motion, hand splints.  Bowel movements if monitoring constipation.

  26. DOES ACTIVITY DIRECTOR NEED FOOD HANDLER’S TRAINING IF WORKING WITH EDIBLES FOR RESIDENTS?  YES. Part of Orientation.  Food Handler Training Documents and Videos Online.  CODE 257

  27. IS THE FOOD SERVICE MANAGER REQUIRED TO HAVE DIETARY MANAGER CERTIFICATION?  NO

  28. WHEN CHANGING LICENSURE FROM RES CARE TO ASSISTED LIVING, DOES THE PHYSICIAN NEED TO REDO REFERRAL, H&P, & MEDICATION ORDERS?  Not required but common practice is to get “Admit to Assisted Living” on monthly order.  Physician order form needs to include all required items. Some items may not have been on Residential Care orders.  Existing history and physical is fine.

  29. WHAT CHEMICALS / CLEANING ITEMS ARE OK TO HAVE IN RESIDENT APARTMENT? DO THEY NEED TO BE LABELED?  Assess resident to determine they can handle the item safely.  No other residents can access chemical.  Cannot be “harmful or fatal if swallowed” if dementia resident can access. (Nail polish remover, dish detergent, deodorant, shampoo, perfume)

  30. DO YOU HAVE ANY TIPS TO IMPROVE OUR QA PROCESS?  Invite pharmacist if medication administration is reoccurring problem. (Involve right people)  “Remind resident to use call light” as a fall prevention measure is inappropriate if resident is confused / forgetful.  Quarterly customer satisfaction measures.  Include survey plan of correction.

  31. ARE LIFTS ALLOWED TO ASSIST IN TRANSFERRING A RESIDENT?  YES. Lifts are a medical device and are not prohibited.  One-person assist.  Staff training required.

  32. HOW ABOUT A TRAPESE OR HALF BEDRAIL USED FOR PULL-UP OR SELF- POSITIONING?  Permissible medical device  No restraining bedrails allowed

  33. WHAT OXYGEN ADMINISTRATION TASKS ARE NURSE AIDES ALLOWED TO DO?  Nurse must set flow as ordered.  Tanks must be secured in holder.  No rules provide clear guidance on who can change tanks.

  34. CAN A FACILITY PROVIDE TRAINING FOR ACTIVITY DIRECTOR OR MUST THEY GO TO SPECILIIZED CLASS FOR CERTIFICATION?  310:663-9-5 (C0952) Each assisted living center shall ensure that staff members providing socialization, activity, and exercise services are qualified by training.  Training must be documented.  Can be formal class or part of orientation.

  35. HOW DO OTC’S IN RESIDENT’S APARTMENT NEED TO BE LABELED?  Keep box with directions.  First and last name.  Physician name and date opened not required.

  36. WHERE CAN I GET COPY OF LIFE SAFETY CODES?  Local, State, Fed Vary. Most Restrictive Applies.  OAC 265:25-1-3 Supplement to LTC Emergency Action Plan (Incorporated National Codes & Standards). Examples:  International Building Code, 2003 Edition  International Fire Prevention Code, 2003 Edition  N FPA #101 Life Safety Code, 2003 Edition

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