Under regulation §483.35 Nursing Services we find the regulatory requirement for sufficient and competent nursing staff at section §483.35(a)(3) which states “The facility must ensure that licensed nurses have the specific competencies and skill sets necessary to care for residents’ needs, as identified through resident assessments, and described in the plan of care”. The intent of this regulation is to “assure that all nursing staff possess the competencies and skill sets necessary to provide nursing and related services to meet the residents’ needs safely and in a manner that promotes each resident’s rights, physical, mental and psychosocial well-being”.
There are many aspects to determining nurse competency. One of the key components described in the regulation’s guidance to surveyors is the ability of nursing staff to be able to “promptly identify changes that may indicate a change in health status”. This ability has also been a common basis of the complaint in many long-term care lawsuits. While it is certainly recognized that not all changes in status are preventable, including resident declines or hospitalizations, the nurse must be able to complete an in-depth assessment, communicate with the MD/APRN, implement the prescribed interventions and document the completion of each of these critical steps.
Other areas of competency identified in the regulation include the following: Resident Rights; Person-centered care; Communication; Basic nursing skills; Basic restorative services; Skin and wound care; Medication management; Pain management; Infection control; and Cultural Competency. With so many areas to address, where do you start? The best place to start is to review the most recent employee evaluation and employee file of each nurse. Priorities should be established based on any areas of weakness or concern identified in the nurse’s evaluation, or in any employee counseling or disciplinary actions noted within their file. Training should focus first on these identified areas, and on any other areas of concern related to nursing care within the facility, such as from recent survey deficiencies, resident or family grievances, or QAPI audits.
Another great place to start in competency training is to review some of the many resources available for tools and training modules that can be utilized in the facility. The Agency for Healthcare Research and Quality (AHRQ) offers training modules in the area of identifying and communicating resident changes in condition. CMS provides resources for assessing nurse competency, via the CMS Nursing Home Staff Competency Assessment Toolkit, found on the CMS website as part of the Civil Money Penalty Reinvestment Program (CMPRP). Proactive also has made multiple competency toolkits available to ease the burden of staff competency training and assessment in the areas of ADLs, Basic Nursing Skills, Behavioral Health, Cognitive Assessment, Cultural Competency, Basic Infection Control, Restorative Nursing Staff, Trauma Informed Care, as well as a Department Specific Competency Checklist. Assuring the competency of the facility staff, especially the licensed nurses, is one of the most effective interventions in providing safe care that meets the resident needs. It is also one of the best ways to prevent survey deficiencies, resident and family grievances, and even the risk of long-term care litigation.
Contact Proactive for assistance with staff development and fulfilling nurse competency requirements.
Blog by Janine Lehman, RN, RAC-CT, CLNC, Proactive Medical Review
Click here to learn more about Janine and the rest of the Proactive team.