The Office of the Inspector General (OIG) released a new data brief, “Trends in Deficiencies at Nursing Homes Show That Improvements Are Needed To Ensure the Health and Safety of Residents.” The brief includes an analysis of nursing home deficiencies cited during CY2013-CY2017 across the United States to identify trends. At CMS Compliance Group, we are routinely tracking and trending survey citations at both the state and national level, so reviewing the report didn’t render any real surprises, but instead reinforced where providers have continued vulnerabilities.
First, the data brief includes the top 10 deficiency types for CY2013-CY-2017:
- Free of Accident Hazards/Supervision/Devices (Former F323/ Current F689)
- Infection Prevention and Control (Former F441/ Current F880)
- Provide Care and Services for Highest Well-Being (Former F309 – Currently identified under multiple tags)
- Food Procurement, Store/Prepare/Serve – Sanitary (Former F371/ Current F812)
- Develop Comprehensive Care Plans (Former F279 / Current F656)
- Drug Regimen is Free from Unnecessary Drugs (Former F329 / Current F757 and F758)
- Label/Store Drugs and Biologicals (Former F431 / Current F761)
- Resident Records – Identifiable Information (Former F514 / Current F842)
- Dignity and Respect of Individuality (Former F241 – Currently identified under multiple tags)
- Investigate/Prevent/Correct Alleged Violation (Former F225 / Current F610)
At the risk of sounding like a broken record, here are the most frequently cited deficient practices identified on standard surveys for 2018 through April 2019:
- F880 Infection Prevention and Control (#2 CY13-17)
- F812 Food Procurement, Store/Prepare/Service – Sanitary (#4 CY13-17)
- F656 Develop CCPs (#5 CY13-17)
- F689 Free of Accident Hazards/Supervision/Devices (#1 CY13-17)
- F761 Label/Store Drugs and Biologicals (#7 CY13-17)
- F684 Quality of Care (This is a catch-all tag that can include some of the issues previously cited under F309 #3 CY13-17)
- F657 Care Plan Timing and Revision
- F758 Free from Unnecessary Psychotropic Meds/PRN Use (#6 CY13-17)
- F641 Accuracy of Assessments
- F550 Residents Rights (#9 – Dignity – is included in this tag)
So, even when we update the tags to the revisions to the RoPs, you can see that the majority of deficient areas have remained relatively consistent all the way since 2013, irrespective of whether the survey process was Traditional, Quality indicator Survey (QIS) or the updated Long-Term Care Survey Process (LTCSP) that became effective November 2017.
OIG’s definition of a “repeat deficiency”
In this document, the OIG stated that it defines repeat deficiencies as one that was cited during five or more separate surveys at a nursing home. Yes, 5 or more times – that is definitely a “repeat,” but more alarmingly, highly indicative of a significant system failure in that area. The OIG found that 31% of nursing homes in the US had a deficiency type that was cited under their definition of “repeat.” Coupling the idea that some facilities have been cited 5+ times for deficient practices related to the same tag with the most frequently cited deficient practices being relatively consistent from CY2013- CY2018 (and some of 2019) lends itself to the idea that facilities may not be taking a hard look at their survey histories and using the results as a compliance tool in the manner that they should be. Surveyors are looking at this data – you should be, too.
