This week’s Ftag of the Week on the CMSCG Blog is F580 Notify of Changes, which is part of the Residents Rights regulatory group. This requirement is relatively straightforward as far as requirements go, however, it is widely cited across the country, including at the more severe levels of Scope and Severity, including Actual Harm and Immediate Jeopardy. The regulation at F580 requires that facilities provide immediate notification of several things to the resident, consult with the resident’s physician and notify the resident representative (as required). These include:
- When a resident has an accident that results in injury and may require physician intervention (including, per the Interpretive Guidance (IG), chest pain, loss of consciousness and other signs/ symptoms of a heart attack or stroke)
- When the resident experiences a significant change in status (physical/mental/psychosocial)
- When there a significant change in treatment required
- When the resident will be transferred or discharged from the facility. The facility needs to provide the appropriate documentation (required under F622) is available for the physician to review. This include the documentation in the medical record.
- When the resident will be admitted to a composite distinct part of the facility
Notification to the resident and resident representative must promptly be made when there is a change to the resident’s room or roommate or a change to the resident’s rights. The facility is also responsible for ensuring that it records and periodically updates contact information for the resident representative (phone/mailing address/email). The Interpretive Guidance (IG) states that even if a resident is competent, the resident representative should be notified of significant changes in health status because the resident may not be able to notify them themselves. Likewise, even if the facility notifies the resident representative because the resident does not have decision-making capacity, the facility is responsible for telling the resident what is happening to him/her.
How It’s Being Cited
Some frequently cited issues that have been cited as either Actual Harm or Immediate Jeopardy level deficiencies include:
- Failure to notify the physician after a resident experienced:
- Respiratory distress
- Change in condition – vital signs, abnormal lab values
- Significant weight loss
- Pain
- Meds not administered due to unavailability
- Failure to notify licensed staff after resident experienced:
- Fall with injury
- Pain during wound care
- Food/liquid intake reduced
This is, from many perspectives, a “gotcha” deficiency. We simply fail to communicate in a timely and effective manner with the representative or the physician. A facility should consider developing a list of changes/concerns/criteria for which physician and representative notification should be conducted and it should be comprehensive. There also needs to be a clear understanding by all staff of what is considered an acceptable timeframe for carrying out the notification. Pick up that phone and make those notification calls and document this contact in the medical record.
