This week’s “Ftag of the Week” is F675 – Quality of Life. This regulation, which is part of the similarly named Quality of Life regulatory group, is a concept that is familiar to all providers, but there’s an important nuance to how and when this Ftag can be cited under the updated Requirements of Participation (RoPs).
The Interpretive Guidance at F675 specifically states:
“Noncompliance at F675 identifies outcomes which rise to the level of immediate jeopardy and reflect an environment of pervasive disregard for the quality of life of the facility’s residents. This can include the cumulative effect of noncompliance at other regulatory tags on one of more residents. To cite noncompliance at F675, the survey team must have evidence that outcomes at other regulatory tags demonstrate a pervasive disregard for the principles of quality of life.”
Further, the Interpretive Guidance (IG) notes: “Quality of Life at F675 should not automatically be cited when noncompliance has been identified in Resident’s Rights/ Quality of Care/ Abuse-Neglect or other regulatory tags, unless the cumulative effect of the noncompliance creates an environment that reflects a complete disregard of one or more residents’ well-being and rises to the level of Immediate Jeopardy.”
So, it appears that this tag should be cited for IJ-level citations only, yet a review of citations from 11/28/2018 through 5/30/18 shows that across the country, F675 has been cited a total of 77 times. Only 3 of those citations were at an IJ-level (2 Ks and 1 J). This is probably due to its association with the previously widespread citing of the old F309 that was used as the catch-all for all types of deficient practices.
However, this regulation’s intent is to ensure that facilities have created an environment that “humanizes and individualizes each resident’s quality of life” by ensuring that all staff not only understand the principles of quality of life, but also honor and support these principles for their residents. This includes providing person-centered care and ensuring residents receive the necessary care and services consistent with their comprehensive assessments and care plans. The Interpretive Guidance stresses the importance of respect and dignity and the residents’ ability to have control over their lives, including choices of mealtimes, activities, clothing and sleep/wake times. Facility leadership is expected to ensure that staff are adhering to this culture, including through observation of verbal and nonverbal interactions between the staff and residents to identify actions/attitudes that do not recognize/value the resident.
It would be worth your while to take the time to read the section of this regulation that is titled “The Link between Noncompliance at other Regulatory Tags and Noncompliance at Quality of Life.” The examples reflect issues that you don’t want to ever have identified in your facility.
CMS Compliance Group provides survey consulting services including Immediate Jeopardy assistance, Plan of Correction development and implementation and Directed Plan of Correction/ Directed InService assistance to nursing facilities across the United States. Contact us to learn more.