Category: CMS Memo

Cardiopulmonary Resuscitation (CPR) in Nursing Homes – Guidance Clarification Update

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Guidance Clarification Update February 21, 2014

CMS Memo S&C: 14-01-NH

The Section for Long-Term Care Regulation (SLCR) wants to make certified providers aware that updated guidance from CMS (S&C: 14-01-NH) now requires “certification” of some nursing home staff as part of the nursing home’s compliance with regard to CPR.  Previously, if a question arose during a federal regulatory process regarding whether someone could perform CPR properly, a surveyor may have needed to ask for an explanation of appropriate technique from some available staff member to verify compliance with that requirement, but verifying the certification of a particular staff member typically was not necessary.

This most recent memo states that “certification” of some staff members is mandatory, but the memo does not clarify which certifying agencies are acceptable (i.e., American Heart Association).  SLCR and the Kansas City Regional CMS office requested a clarification of this point.

We have now received guidance indicating that the purpose of this memo was to, “…ensure that facilities do not implement facility-wide ‘no CPR’ policies and that facilities have CPR-certified staff available at all times,” but that CMS does not intend to review or approve all certification agencies.

A wide range of organizations offer CPR certification – some are based online and some are conducted in-person.  To this point, CMS has clarified that while S&C: 14-01-NH does not require the use of any specific certifying agency, there are two components that are required with regard to CPR certification:

  • The certification must be designed for healthcare providers (therefore, CPR courses for laypersons which teach chest compressions, but not mouth breathing, are not sufficient); and
  • Nursing home policies should address how staff members should maintain and document their CPR certification.

The American Heart Association certification is acceptable under this guidance, but it is not the only acceptable certification.  Many homes in Missouri are currently obtaining CPR certification through the American Safety & Health Institute (ASHI), which is also acceptable, as are others, as long as they are designed for professional healthcare providers.

You may view the memo here: CMS Memo S&C: 14-01-NH, or visit www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions.html.

Safety Reminders: Holiday Decorations

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It is that time of year when people are decorating their homes and businesses with festive décor and anticipating upcoming holiday celebrations.  Residents and staff in your care home also look forward to festivities and enjoy holiday decorations.  It is important for residents, staff and visitors to carry on traditions and to feel a sense of joy and peace we all want this time of year.

The Section for Long-Term Care Regulation (SLCR) wants to help you and your residents have a safe holiday season by sending out the following safety tips, references and regulatory reminders.

Fires or other accidents are not something anyone wants! 

Safe decorations include:

  • Artificial Christmas trees, and decorations that are non-combustible or flame retardant.
  • UL approved decorative lighting (use in supervised areas and turn off when not in use).
  • UL approved outdoor lighting.
  • Holiday decorations, including evergreen wreaths, ornaments, photos, etc. can be used on resident’s doors, and in hallways, as long as they do not exceed 3 ½” in depth and they are not blocking the entrances or exits.*

*Any combustible decorations hung from doors or walls in corridors may be used with a waiver.  Non-rated combustible decorations cannot exceed 20% of the wall space in an exit egress corridor.

SLCR published an article regarding holiday decorating in the winter 2011 edition of the quarterly newsletter.  Please visit http://health.mo.gov/seniors/nursinghomes/providerinfo.php.

Although the 2000 Edition National Fire Protection Association (NFPA) 101® Life Safety Code (LSC) is the official reference, the 2012 Edition contains some less restrictive requirements.  Please refer to the CMS memo regarding waivers here: CMS Memo S&C 13-58-LSC 2000 Edition National Fire Protection Association (NFPA) 101® Life Safety Code (LSC) Waivers, or visit the CMS website at www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions.html.

Prohibited decorations include displays, hangings, and other decorations that block exits, visibility of exits, or fire protection appliances.  Never hang decorations from fire sprinkler heads or pipes.

NFPA 101, Section 19.7.5.4:  Combustible decorations shall be prohibited in any health care occupancy unless they are flame retardant.

NFPA 101, Section 7.1.10.1:  Means of egress shall be continuously maintained free of all obstructions or impediments to full instant use in the case of fire or other emergency.

NFPA 101, Section 7.1.10.2.1:  No furnishings, decorations, or other objects shall obstruct exits, access thereto, egress therefrom, or visibility thereof.

 

Please note, some county or city local ordinances may also require compliance with more restrictive standards, including the International Fire Code (IFC).

 

  • F323:  Electrical Safety – Any electrical device, whether or not it needs to be plugged into an electric outlet, can become hazardous to the residents through improper use or improper maintenance.  Electrical equipment such as electrical cords can become tripping hazards.  Halogen lamps or heat lamps can cause burns or fires if not properly installed away from combustibles in the resident environment.  The Life Safety Code prohibits the use of portable electrical space heaters in resident areas.

 

 

  • Can candles be used in nursing homes under supervision, in sprinklered facilities?

CMS Memo S&C-07-07:  Nursing Home Culture Change Regulatory Compliance Questions and Answers

Answer: Regarding the request to use candles in sprinklered facilities under staff supervision, National Fire Protection Association data shows candles to be the number one cause of fires in dwellings.  Candles cannot be used in resident rooms, but may be used in other locations where they are placed in a substantial candle holder and supervised at all times while they are lighted.  Lighted candles are not to be handled by residents due to the risk of fire and burns.

This holiday season, consider using battery-operated flameless candles.  They look and smell real!  Learn more about candle fire safety from the U.S. Fire Administration at www.usfa.fema.gov/citizens/home_fire_prev/holiday-seasonal/holiday.shtm.

If you have any questions regarding the Life Safety Code, please contact SLCR at 573-526-8524.  We wish you a wonderful and safe holiday season.

Nursing Home Quality Initiatives – Questions and Answers

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The Centers for Medicare & Medicaid Services (CMS) and Advancing Excellence in America’s Nursing Homes national campaign coordination group developed a set of common questions and answers for nursing homes, in order to clarify how some of the many initiatives relate to and are aligned with each other.  The purpose is to help nursing homes better understand how to participate in and benefit from various initiatives.

  • Quality Assurance and Performance Improvement (QAPI)
  • National Nursing Home Quality Care Collaborative (NNHQCC)
  • National Partnership to Improve Dementia Care in Nursing Homes
  • Advancing Excellence in America’s Nursing Home’s Campaign
  • Alignment of Quality Initiatives

Questions include:

  • Must nursing homes use CMS QAPI tools and resources to be considered in compliance with the QAPI regulation?
  • What is the National Nursing Home Quality Care Collaborative (NNHQCC)?
  • What is a LAN?
  • How does the mission of the National Partnership to Improve Dementia Care in Nursing Homes align with non-pharmacological, person-centered care approaches?
  • What does a nursing home have to do to become part of Advancing Excellence?
  • How does QAPI overlap or align with topic specific initiatives such the NNHQCC, the National Partnership to Improve Dementia Care in Nursing Homes, and Advancing Excellence in America’s Nursing Homes?
  • If we participate in the NNHQCC or Advancing Excellence or the National Partnership to Improve Dementia Care in Nursing Homes, are we implementing QAPI?

Find the answers to these questions and more – click on the link below

CMSFAQsNHQualityInitiatives

This document is also available for download by visiting http://www.nhqualitycampaign.org/.

Cardiopulmonary Resuscitation (CPR) in Nursing Homes

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CMS Memo S&C: 14-01-NH

The Section for Long-Term Care Regulation wants to make certified providers aware that this Memo requires “certification” of some nursing home staff as part of the nursing home’s compliance with regard to CPR.  CMS’ guidance had previously been that an on-duty staff member be able to perform CPR appropriately at all times.  If a question arose during a federal process regarding whether someone could perform CPR properly, a surveyor may have needed to ask for an explanation of appropriate technique from some available staff member to verify compliance with that requirement, but verifying the certification of a particular staff member typically wasn’t necessary.

One point that remains unaddressed in this new S&C Memo is that many different CPR training agencies offer “certification” of their own, and this Memo doesn’t specify which agency’s certifications are acceptable to CMS and which are not.  SLCR has requested a clarification of this point from the CMS Central Office, and so has the Kansas City Regional CMS office.  Neither of our offices have received a response.  When we receive further guidance, we will provide it to you via this Listserv.  Until then, we will not be altering our current survey practices, but we want to make providers aware that this new S&C Memo has been issued by CMS, and that depending on their answer to our questions, it’s likely that some of your staff may need to obtain CPR certification with very short notice.

Because this memo references the American Heart Association as a standard-setting organization with regard to CPR, it is our belief that provider certification through the AHA will almost certainly be deemed acceptable by CMS.  Whether other certifications will suffice is less clear at this time.  As soon as we have some clarification on this point, we will share it with you.  We apologize that we can’t offer more specific guidance at this time, and appreciate your patience.

View the CMS Memo S&C: 14-01-NH here:  Survey-and-Cert-Letter-14-01 or click here. 

UPDATED GUIDANCE HAS BEEN POSTED – PLEASE REFER TO:

https://wp2.mo.gov/health-ltc/2014/02/24/cardiopulmonary-resuscitation-cpr-in-nursing-homes-guidance-clarification-update/

 

Transition Guidelines for SNF PPS Policy and MDS 3.0 Effective October 1, 2013

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The memo “Transition for Implementation of FY 2014 SNF PPS MDS 3.0 Policy Changes” describing the transition guidelines for SNF PPS policy and MDS 3.0 changes effective FY 2014 related to the final rule, is located on the SNF PPS Spotlight webpage, under the Downloads section: www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/SNFPPS/Spotlight.html.

Reminder: MDS 3.0 Discharge Assessments

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This reminder is available on the CMS MDS 3.0 RAI Manual webpage:

www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/MDS30RAIManual.html.

CMS is providing an opportunity to rectify the current situation related to missing and incomplete discharge assessments.  Homes must complete missing discharge assessments as soon as possible, but no later than September 30, 2013.  Homes can self-audit their MDS assessments by accessing the CASPER system and requesting a MDS 3.0 Resident Roster or a MDS 3.0 Missing Assessment Report.  If you need assistance accessing or interpreting these reports, please contact the State MDS Unit at 573-751-6308, joan.brundick@health.mo.gov or 573-522-8421, denise.mueller@health.mo.gov.

New Data Show Antipsychotic Drug Use is Down in Nursing Homes Nationwide

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Nursing homes are using antipsychotics less and instead pursuing more patient-centered treatment for dementia and other behavioral health care, according to new data released on Nursing Home Compare in July by the Centers for Medicare & Medicaid Services (CMS).  Please read this press release on the CMS website:  www.cms.gov/Newsroom/MediaReleaseDatabase/Press-Releases/2013-Press-Releases-Items/2013-08-27.html.

Minimum Data Set (MDS) 3.0 Discharge Assessments – Not Completed and/or Submitted

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Completing MDS 3.0 discharge assessments has been a requirement since October 1, 2010.  However, many homes are not completing these assessments. 

The Centers for Medicare & Medicaid Services (CMS) issued a Survey and Certification memorandum on August 23, 2013, which clarifies the assessments are required.  The memo helps surveyors understand what nursing homes should do when they have inactive residents on their resident roster, and how nursing homes can ensure compliance with these requirements. 

CMS is providing an opportunity to rectify the current situation related to missing and incomplete discharge assessments.  Homes must complete missing discharge assessments as soon as possible, but no later than September 30, 2013.  Homes can self-audit their MDS assessments by accessing the CASPER system and requesting a MDS 3.0 Resident Roster or a MDS 3.0 Missing Assessment Report.

If you need assistance accessing or interpreting these reports, please contact the State MDS Unit at 573-751-6308, joan.brundick@health.mo.gov or 573-522-8421, denise.mueller@health.mo.gov.

Please review the CMS Memo – Ref: S&C: 13-56-NH online at www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions-Items/Survey-and-Cert-Letter-13-56.html.

CMS Memorandum – Public Release of the Five-Star Quality Rating System Three-Year Report

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Ref: S&C:  13-44-NH:  To access this report, visit the website at www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/FSQRS.html

Scroll to the Downloads Section,

select: NHC Five Star Quality Rating System Report 2009-2011 [PDF, 2MB]

View the CMS memo here: www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions-Items/Survey-and-Cert-Letter-13-44.html?DLPage=1&DLSort=2&DLSortDir=descending

CMS Memorandum – Changes to the Nursing Home Compare Website July 2013

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CMS Memorandum – Changes to the Nursing Home Compare Website

Ref: S&C: 13-43-NH:  In July 2013, all users of the Nursing Home Compare website that wish to download nursing home data will be redirected to the new website, https://data.medicare.gov/.  The website will contain new data layouts and additional nursing home data not previously available.

View the CMS memo here: www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions-Items/Survey-and-Cert-Letter-13-43.html?DLPage=1&DLSort=2&DLSortDir=descending

CMS Memorandum – Reminder: Access and Visitation Rights in Long Term Care (LTC) Facilities

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Ref: S&C: 13-42-NH:  This memorandum reviews current interpretive guidelines for F-Tag 172, reiterating resident rights surrounding access and visitation.

View the CMS memo here: www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions-Items/Survey-and-Cert-Letter-13-42.html?DLPage=1&DLSort=2&DLSortDir=descending

New MDS 3.0 RAI Manual Effective May 20, 2013

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Nursing homes are expected to be aware of and implement the most current CMS policies regarding the MDS 3.0 RAI Manual.  The following website lists changes on change tables for quick reference.  The actual manual pages that have changed are also included.  Please visit the CMS website: www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/MDS30RAIManual.html and scroll to the Downloads Section:

MDS 3.0 RAI Manual v1.10 Replacement Manual Pages and Change Tables.zip [ZIP, 5MB]

MDS 3.0 RAI Manual v1.10 and Change Tables.zip [ZIP, 22MB]

MDS 3.0 RAI Manual v1.10 Appendix B Rev 5.15.2013.pdf [PDF, 108KB]

Please note the effective date is May 20, 2013, although previously noted as May 8, 2013 on the CMS website.  If you have any questions, you may contact Joan Brundick, BSN, RN, State RAI Coordinator, Missouri Department of Health and Senior Services, Telephone (573) 751-6308 or email joan.brundick@health.mo.gov.

Hand in Hand: A Training Series for Nursing Homes – SLCR Reminder

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(Person-Centered Care of Persons with Dementia and Prevention of Abuse)

Section 6121 of the Affordable Care Act requires the Centers for Medicare & Medicaid Services (CMS) to ensure that nurse aides receive regular training on caring for residents with dementia and on preventing abuse.  CMS created Hand in Hand training in order to address the annual requirement for nurse aide training.  While homes are not required to use Hand in Hand for their dementia and abuse training, it is a wonderful, free resource that CMS has provided to every nursing home in the nation.  CMS sent the packet containing videos and training techniques to all homes in December of 2012.

The Section for Long-Term Care Regulation realizes that the information appears voluminous, but encourages homes to take a closer look and try to implement at least some of the videos for your direct care staff.  The videos show staff how to relate to residents with dementia and how to appropriately respond to behaviors.  The training is also timely with the CMS initiative to reduce the use of antipsychotics in nursing homes.  The videos show staff how to get to know the person and understand why they are behaving a certain way, so that they can use alternative methods, rather than asking for an antipsychotic medication.  Everyone’s time is valuable; however, there is no sense in reinventing the wheel when CMS has done it for you.  We encourage you to take a look at the Hand in Hand information and try to implement some of the videos in your required training on dementia and abuse prevention.

http://www.cms-handinhandtoolkit.info/Index.aspx

 

CMS Promotes New Dining Practice Standards

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CMS Memo S&C: 13-13-NH

The Centers for Medicare and Medicaid Services (CMS) has issued a survey and certification memo announcing the New Dining Practice Standards.  An accompanying training video is available for surveyors and the public.  The New Dining Practice Standards document is available for download by visiting Pioneer Network at www.pioneernetwork.net/Providers/DiningPracticeStandards/. 

Please view the Dining Standards Open Letter 03-15-2013 to our readers.

Quality Assurance and Performance Improvement (QAPI)

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Section 6102(c) of the Affordable Care Act requires that all nursing homes develop Quality Assurance and Performance Improvement (QAPI) programs.  These are different from Q.A. programs. 

QAPI emphasizes prevention of adverse events rather than reaction to adverse events.  It emphasizes promotion of safety and quality throughout the entire organization (not just nursing) and focuses on reducing risks to residents and caregivers both. 

Please visit the Centers for Medicare & Medicaid Services (CMS) website for more information at cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/QAPI.html. 

Primaris is Missouri’s federally designated Quality Improvement Organization (QIO).  QAPI information is available online at www.primaris.org/qapi. 

More updates regarding QAPI will be announced over the next several months.

Insulin Pen Safety – One Insulin Pen, One Person

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The Centers for Disease Control (CDC) has been working to promote safe use of insulin pens, in light of growing awareness of the risk of reuse.  Insulin pens are meant for one patient only, but there have been recent occurrences of insulin pens being used for more than one patient.  The CDC’s injection safety campaign recently introduced a brochure and poster for clinicians and patients about the safe use of insulin pens.  The brochure and poster as well as other resources can be found on the Insulin Pen Safety web page.

                                      www.oneandonlycampaign.org/

Which Employees Must be Reported on the CMS Long Term Care Facility Application for Medicare and Medicaid?

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The Section for Long-Term Care Regulation has received questions regarding which facility staff must be reported on the CMS-671 Long Term Care Facility Application For Medicare and Medicaid form. 

Only facility staff should be reported on the CMS 671.  Homes should not report hours for feeding assistants, hospice staff (even if the company is owned by the corporation) or private-duty aides that are paid by the residents’ family. 

If the facility director of nursing or administrator worked 90-hours during the last two weeks, then it should be reported as such.  Always report actual hours worked. 

Contract staff should also be reported.  The form instructions state:  “Contract includes individuals under contract, (e.g., a physical therapist) as well as organizations under contract (e.g., an agency to provide nurses).” 

For nursing homes that are not fully certified, report staffing hours for certified beds only.  The form instructions state:  “For the purpose of this form ‘the facility’ equals certified beds (i.e. Medicare and/or Medicaid certified beds).”  

Please note that staffing hours included in the Five-Star Quality Rating System are obtained from the CMS 671 application at the time of facility recertification. 

It is important to report staffing hours accurately.  Certain CMS programs and reports are dependent upon the data homes report.  If you have any questions, you may contact Joan Brundick, State RAI Coordinator at 573-751-6308 or send an email to joan.brundick@health.mo.gov. 

The CMS 671 form is available online: http://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/CMS-Forms-Items/CMS006581.html.

CMS Reminder: Revisions to Forms 672 and 802

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Effective December 1, 2012 CMS instructed surveyors to return to the “Traditional Survey Process” of reviewing Quality Measures during offsite preparation.  

This change also implemented the use of the new “Form CMS 802 (04/12) ROSTER/SAMPLE MATRIX” and “Form CMS-802P (04/12) ROSTER/SAMPLE MATRIX INSTRUCTIONS FOR PROVIDERS.”  

This change has also implemented instructional updates to “Form CMS 672 (05/12) RESIDENT CENSUS AND CONDITIONS OF RESIDENTS.”  

If your facility automates forms from the MDS software, please ensure to present the new forms to the facility surveyors.  You may need to contact your vendor if your software does not generate the new forms.  

Facilities are required to utilize the new forms.  Upon survey entrance, surveyors will provide the administrator with the forms to be completed.  The new forms are also available for download online:  www.cms.gov/Medicare/CMS-Forms/CMS-Forms/CMS-Forms-List.html.