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Ask Proactive – Your obligation to report concerns
Q: I am a floor nurse and have a concern about a coworker’s practices at work. When I am on the medication cart that she normally works, I find many medications that still have blisters packs that are full, and unopened inhalers, eye drops, etc. She and I are friends...
Survey Ready! F895 LTC Compliance and Ethics Program Requirements
Oversight, Outbreaks, Overpayments…Oh My! It seems the LTC industry has no shortage of potential pitfalls knocking at the door. October 24, 2022 has come and gone, with the long-awaited phase 3 surveyor interpretive guidance now in effect for LTC providers. This...
Ask Proactive – Does the ABN Have to be Issued When Therapy Ends?
Q: When someone is still on Med A benefits and the therapy team reduces or ends one type of therapy but not all types, does the ABN need to be given each time? A: The notices aren’t required when therapy reduces or ends services, but rather when the SNF...
Revisions to Special Focus Facility (SFF) Program
On Oct. 21, 2022, CMS issued QSO-23-01-NH, announcing revisions to the Special Focus Facility (SFF) program with an emphasis on improving the quality of care that residents living in SFF receive. The changes to the program aim to address facilities that remain in the...
Survey Enforcement Remedies: Directed In-Service Training
Q: My facility just completed our annual survey and is in denial of payment until a Directed In-Service training is completed. What is a Directed In-Service training and how do we ensure compliance? A: Directed In-service training is one of the enforcement...
Avoiding Deficiencies at F758 – Psychotropic Drugs
The prevalence of psychotropic drugs in nursing homes has increased in recent years in part due to the worsening of emotional and behavioral disorders exacerbated by the restrictive measures of the COVID-19 pandemic.[1] Consequently, F758 Psychotropic Drugs is one of...
F699 Trauma-Informed Care
F699 Trauma-informed Care is one of the many areas with changes to the LTC Survey process effective October 24th -- is your facility prepared? According to SAMHSA - Substance Abuse and Mental Health Services Administration seventy percent of adults in the United...
Ask Proactive – How much is the ALJ Appeal Amount in Controversy for 2023?
Q: How much is the ALJ Appeal Amount in Controversy for 2023? A: The amount in controversy (AIC) threshold amount for Medicare ALJ appeals will continue to be $180.00 for CY2023 and the AIC for Judicial Review will increase to $1850.00 Learn more Angie Hamer,...
Ask Proactive – What are some of the most significant changes to the new RoP Interpretive Guidance for Abuse, Neglect & Exploitation?
Q: What are some of the most significant changes to the new RoP Interpretive Guidance for Abuse, Neglect & Exploitation? A: Some of the most significant changes to the new RoP Interpretive Guidance (IG) for Abuse, Neglect...
LTC Infection Prevention & Control Outbreak Management—Start Here!
Infection surveillance is critical in long term care. It enables the effective Infection Preventionist to monitor facility trends and act proactively in response to potential outbreaks. CMS states that The facility must establish a system for surveillance based upon...
F895 Compliance and Ethics Programs
Revised long term care surveyor guidance for F895 Compliance and Ethics Programs was released June 29, 2022. CMS will begin enforcing F895 on October 24, 2022 and has released specific surveyor guidance and updates to Appendix PP to guide preparations. Effective...
Ask Proactive – MDS Section I—ICD.10 Diagnosis Code Error
Q: I’ve noticed when reviewing resident diagnoses for MDS Section I that several of the diagnoses are suddenly showing an error message. How do I correct this? A: CMS has revised several ICD-10 codes for the 2023 fiscal year....
Updated COVID-19 Guidance-Key Takeaways
Over the past week, CMS and CDC issued updated guidance related to COVID-19. On September 23, 2022, CMS updated the QSO memos 20-38-NH related to nursing home testing requirements and 20-39-NH related to nursing home visitation. Key changes/additions to the CMS...
Ask Proactive – The Medicare and Medicaid Services (CMS) updated the surveyor guidance found in Appendix PP of the State Operations Manual on June 29, 2022. Surveyors will use critical element (CE) pathways to aid in the investigation of many of the federal tags. When will the new guidance begin?
Q: The Medicare and Medicaid Services (CMS) updated the surveyor guidance found in Appendix PP of the State Operations Manual on June 29, 2022. Surveyors will use critical element (CE) pathways to aid in the investigation of many of the federal tags. When will the new...
F686 Pressure Ulcers—Where Facilities Go Wrong
In Appendix PP of the State Operations Manual, Tag F686 for Treatment/Services to Prevent/Heal Pressure Ulcers outlines the following requirements: 483.25(b)(1) Pressure ulcers. Based on the comprehensive assessment of a resident, the facility must ensure that—(i) A...