QAPI & Health Equity: What New Surveyor Guidance Means for Nursing Homes
If you’ve worked in long-term care for more than a minute, you understand that QAPI is the backbone of quality improvement. But there’s a new layer added with the recent CMS updates— health equity is now explicitly baked into QAPI expectations. So what does this mean for nursing homes? And more importantly, how should we respond?
Let’s break it down.
First, What’s New?
CMS released updated surveyor guidance requiring nursing homes to integrate health equity into their QAPI framework. This isn’t just a recommendation—it’s something surveyors will actively be looking for as part of the health inspection process. Health equity, in this context, means making sure all residents—regardless of race, ethnicity, language, disability, sexual orientation, or socioeconomic status—receive high-quality care that meets their individual needs. Simply put, cookie-cutter care is out. Culturally responsive, personalized care is in.
Why This Matters
If we’re honest, health disparities have existed in long-term care for decades. Some residents may be less likely to report pain. Others may experience language barriers that impact medication education or participation in care planning. Still others may feel unseen when their spiritual or cultural practices aren’t acknowledged. The new guidance calls attention to these systemic issues and makes addressing them a required part of your quality program—not an optional one.
What Surveyors Will Be Looking For
Under the revised guidance, surveyors will expect to see:
- Evidence that your QAPI plan includes health equity goals
- Use of facility data to identify disparities in outcomes, satisfaction, or services (think: falls, pressure injuries, or psychotropic med use by race or language group)
- Resident and family input on perceived barriers to care
- Staff training on bias, cultural humility, and communication differences
- Action plans developed through QAPI PIPs (Performance Improvement Projects) that address any inequities found
Responding to this Guidance
Your facility likely already has pieces of this in place, but likely need to consider how best to update systems to formalize and effectively document measures being taken as part of your QAPI process. Here’s where to start:
- Pull your data apart – Break data down by race, language, disability status, etc. Look for trends and ask: Who’s having better or worse outcomes? Who’s using services less?
- Talk to your residents and families – Include underrepresented voices. Ask about any barriers to care, communication gaps, or cultural needs being unmet.
- Update your PIPs – Choose one health equity issue and tackle it head-on. Document your plan, your monitoring, and your progress. That’s QAPI in action.
- Train your team – Make sure frontline staff know how to identify and respond to health equity concerns. Bias isn’t always intentional, but it can always be addressed.
Taking Action
This isn’t just another box to check. When done well, embedding health equity into the QAPI program creates a safer and ultimately more effective care environment. And that benefits every resident. Need Help? Proactive’s QAPI Certified Professional (QCP) consultants help facilities build QAPI programs that are not only compliant but meaningful—and that includes addressing health equity the right way. If you’re unsure where to start or how to dig into your data, reach out. Let’s make quality improvement personal and powerful.
Written By:
Shelly Maffia, MSN, MBA, RN, LNHA, QCP, CHC, CPC, CLNC
Director of Regulatory Services
Proactive LTC Consulting
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