News / Blog
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If I Were Your Compliance Officer
Our office regularly receives urgent calls from providers in crisis. We are in the business of coming alongside nursing facilities to shoulder a portion of the burden, drive corrective actions and assist to remedy problem situations. Given the choice and resources,...
MDS 3.0 Refresh: Mastering the Art of Coding Accuracy
Compliance, Accuracy, Quality. These are words we’ve heard over and over in long-term care. They are part of our everyday regulatory landscape and are essential to MDS data integrity. Despite two years under our belts operating under the PDPM payment model, data shows...
Ask Proactive – What are some best practices for residents who refuse care?
Q: What are some best practices for residents who refuse care? A: In the CMS State Operations Manual – Appendix PP in F 578 §483.10(c)(6), (c)(8), (g)(12) CMS has provided guidance regarding resident refusals: While the resident also has the right to refuse any...
2022 Medical Review in Full Swing
While nursing homes across the nation are seeing a significant decline in COVID-19 cases, providers are reporting a sharp increase in medical review. The most prominent activity includes RAC (Recovery Auditors Contractor) reviews and TPE (Targeted Probe &...
Ask Proactive – What should be done if a PPS 5-Day assessment completed for Managed Care is submitted to CMS?
Q: What should be done if a PPS 5-Day assessment completed for Managed Care is submitted to CMS? A: Assessments that are completed for purposes other than OBRA and SNF PPS reasons are not to be submitted, e.g., private insurance, including but not limited to...
Ask Proactive – I’ve assumed a new role that requires me to audit our compliance with reporting to NHSN. The instructions for completion of the LTCF COVID-19 module are not clear in some areas. For example, we are the designated COVID-19 unit amongst two sister facilities. If the patient acquires COVID in my sister facility, then transfers to my facility, and passes away due to the infection, do I have to count this as a resident COVID death in my facility?
Q: I’ve assumed a new role that requires me to audit our compliance with reporting to NHSN. The instructions for completion of the LTCF COVID-19 module are not clear in some areas. For example, we are the designated COVID-19 unit amongst two sister facilities. If the...
F761 Label/Store Drugs & Biologicals
F 761 Label/Store Drugs & Biologicals is consistently a “Top 10” deficiency. Compliance with F761 is complicated by the vast number of medications and related supplies that facilities must utilize each day, along with the multiple places they must be stored,...
Biden Announces Nursing Home Reforms
Biden’s March 1st State of the Union speech included a promise to bring Nursing Home Industry Reforms including minimum staffing requirements, enhanced nursing home oversight, and greater transparency of facility ownership with a focus on private equity firms. The...
Ask Proactive – We have a patient who received a skilled stay (34 days) using the spell of illness waiver (related to positive COVID condition and clinical needs). She just returned from the hospital outside her 30-day window, but still has 38 days remaining in the benefit period. Can we skill her again? How many times can we use the waiver for a patient?
Q: We have a patient who received a skilled stay (34 days) using the spell of illness waiver (related to positive COVID condition and clinical needs). She just returned from the hospital outside her 30-day window, but still has 38 days remaining in the benefit period....
Ask Proactive – A resident was admitted with a pressure injury (PI) that was unstageable because it was covered with slough and eschar. I coded it on the admission MDS under M0300F(Unstageable Pressure Ulcers Related to Slough and/or Eschar). I’m now doing a quarterly and the slough has been debrided, but there is still a lot of eschar. Do I still code it as unstageable on the MDS?
Q: A resident was admitted with a pressure injury (PI) that was unstageable because it was covered with slough and eschar. I coded it on the admission MDS under M0300F(Unstageable Pressure Ulcers Related to Slough and/or Eschar). I’m now doing a quarterly and the...
Avoiding the #2 Survey Tag: F812 Food Procurement
Based on 2021 Survey Data, F-Tag 812: Food Procurement was the second most cited deficiency on annual surveys and the 5th most cited overall. So far, in 2022, it has been the #1 deficiency cited on annual survey and the 4th most cited overall. (Source: S&C's...
Guidance on Precautions for Unvaccinated Staff
According to CMS, facilities are required to “ensure that staff who are not yet fully vaccinated, or who have a pending or been granted an exemption, or who have a temporary delay as recommended by the CDC, adhere to additional precautions that are intended to...
Care Planning for Fall Prevention
Falls in nursing homes are an unfortunate, yet common occurrence. Studies show that approximately half of nursing home residents in the United States fall each year, and a 2014 report by the Office of the Inspector General found that nearly 10% of adverse events...
Ask Proactive – Under the NHSN Data Reporting, who is included in contracted and vendor HCP (healthcare personnel) for vaccination reporting?
Q: Under the NHSN Data Reporting, who is included in contracted and vendor HCP (healthcare personnel) for vaccination reporting? A: After the NHSN COVID-19 Vaccination Team held webinars in November 2021 that reviewed frequently asked questions (FAQs) and data entry...
Top Vulnerabilities in SNF Infection Prevention and Control Programs
Is your facility at risk for one of the top vulnerabilities in SNF IPC programs? With the ongoing COVID-19 public health emergency, CMS has made Infection Prevention and Control programs (IPC) a significant focus of survey efforts. Surveys are bringing to light many...