This week’s “Ftag of the Week” on the CMSCG Blog is F687 Foot Care. This regulation was effective November 28, 2017, so by now you should have a sound system in place to ensure that proper treatment and care is being provided to residents to maintain their mobility as well as optimal foot health. Care and treatment should meet professional standards of practice, including having an individualized plan to prevent complications associated with the resident’s overall medical condition. A facility also has a responsibility to assist a resident, if necessary, in making appointments to visit a qualified person as well as help with arranging for transportation to and from such outside appointments.
The Intent section of this regulation states that foot care includes treatment to prevent complications from a variety of conditions that can affect optimal foot health. The examples provided of diabetes, peripheral vascular disease and immobility are all conditions that should be evaluated and addressed in the plan of care. Remember that these examples are not the only conditions or complications that can affect foot health.
The Interpretive Guidance (IG) clarifies that treatment includes preventive care being provided so that podiatric complications can be avoided in residents who have complex medical conditions such as those noted above, as they are more prone to developing foot problems. The IG reinforces that toe nail clipping for those residents without complicating diseases should be provided by staff who have been educated and trained in providing this service. Resident who have complicating conditions need to have a referral to a qualified professional for toe nail clipping. A podiatrist, a doctor of medicine (MD) and a doctor of osteopathy (DO) are all qualified professionals who can treat foot problems/disorders. A facility needs to ensure that qualified professionals are involved in meeting the foot care needs of all residents.
There are a variety of “probes” that a surveyor will use to assess your compliance with this regulation. One of the probes that should be on your watch list is related to preventive foot care being provided and “to what resident population.” This means that your staff needs to be able to identify those residents at risk for podiatric complications and develop an appropriate foot care plan. Two other probes to keep a lookout for are:
- Is foot care being provided when needed and ordered?
- During observation, surveyors will be observing a resident’s feet for lack of nail care, calluses, corns, ingrown toenails or other conditions that require treatment.
Remember that any condition that affects foot health may and usually impact mobility. A decrease in mobility is not a complication that you want, especially if it is related to not having an appropriate preventive plan of care in place to maintain foot health.