After a brief summer vacation break, it’s time to dive back into our “Ftag of the Week” series on the CMSCG Blog. In this post, we will be reviewing F655 Baseline Care Plan, which is one of the tags in the Comprehensive Resident Centered Care Plan regulatory group. The purpose of this regulation is to help with ensuring continuity of care for the resident, facilitate communication among facility staff, promote resident safety and reduce the likelihood of an adverse event occurring soon after a resident has been admitted to the nursing home.
Baseline Care Plan Requirements
The Baseline Care Plan (BCP) must be developed and implemented within 48 hours of admission and needs to include the necessary healthcare information to properly care for the resident immediately upon admission in order to reduce the likelihood of a negative outcome shortly after admission, such as in the case of a newly admitted resident falling with a resulting fracture. The resident’s admission orders, information provided by the transferring provider, and information gleaned from discussion with the resident/representative should serve as the basis for developing the BCP. The minimum health information required to be included in the BCP is:
- Initial goals based on admission orders
- Physician orders
- Dietary orders
- Therapy services
- Social Services
- If applicable, PASARR recommendations
To highlight the need to ensure that each resident’s Baseline Care Plan includes all the necessary information to ensure the safety and well-being of the resident upon admission, let’s review some actual survey citations to see what can happen when a BCP does not include the required information.
Complaint Survey – F655 S/S: J
A facility was placed in Immediate Jeopardy for failure to develop a Baseline Care Plan for one newly admitted resident and one resident readmitted from the hospital.
- For the newly admitted resident, the facility failure to ensure a BCP was developed that included directions for staff on how to meet the resident’s basic needs, including wound care, dietary needs, assistance with ADLs and fall risks. The resident did not receive wound care or assistance with hygiene and was transferred to the hospital and admitted to ICU for an infection. The resident was observed with multiple areas of skin breakdown, saturated in urine and covered in feces, with an unkempt appearance.
- For a second resident who was readmitted from the hospital with a new catheter, the facility failed to identify that the resident had returned with a new drain and did not develop a BCP related to care of the drain. The resident returned to the ED two additional times with significant electrolyte balances after not receiving the appropriate care.
- It could be argued that this second citation was incorrectly cited at F655 as the BCP regulation is applicable to a new admission not a readmission from the hospital.
Complaint Survey – F655 S/S: J
A facility was placed in Immediate Jeopardy after failing to address and monitor a resident with known sexually aggressive behaviors, including failing to implement measures to address sexually inappropriate behaviors on the resident’s Baseline Care Plan. This resulted in the resident raping a severely cognitively impaired resident on a dementia care unit. The facility was aware of the resident’s behaviors upon admission, but did not ensure other residents were protected.
Baseline Care Plan Summary
Providers are also required to give a summary of the BCP to the resident/representative. Facilities have the option to provide the entire BCP, but if a summary is provided, it must include, at a minimum, this information:
- Resident’s initial goals
- Summary of resident’s medications
- Summary of resident’s dietary instructions
- Any services and treatments to be administered
- Any information that is updated based on the details of the CCP
Regarding the last bullet, the Interpretive Guidance notes that if a comprehensive assessment or CCP identifies a change in the resident’s goals or functioning that was not identified in the BCP, those changes are expected to be incorporated into an updated summary that is provided to the resident/representative. It should also be noted that once the CCP has been developed and implemented for the resident and the necessary updates have been provided to the resident, the written summary of the Baseline Care Plan does not need to be updated or revised further.
Don’t Forget
The Baseline Care Plan needs to capture key resident needs. During an investigation, surveyor probes include the following important point: If the resident experienced an injury or adverse event prior to the development of the CCP, should the Baseline Care Plan have identified the associated risk? It is understandable how facilities have been placed into IJ when this is considered.
Complaint Survey – F655 S/S: J
A facility was placed in Immediate Jeopardy for failure to develop and implement a Baseline Care Plan for a resident who was assessed on admission as required supervision for smoking and assessed as an elopement risk. The BCP did not include interventions for supervised smoking, or supervision and monitoring for the elopement risk, and the resident was ultimately able to leave the facility unsupervised to smoke. The resident was located at a local fire department and transported to the ER with a fractured hand.
Complaint Survey – F655 S/S: J
A facility was placed in Immediate Jeopardy for failure to develop a Baseline Care Plan that included management of a surgical wound and use of an associated assistive device related to a resident’s recent ankle surgery. The boot and wrap placed on the resident post-surgery remained in place for 3 weeks after the resident was admitted to the facility, and were not removed until the resident went for a follow-up visit to the surgeon’s office. When the boot was removed, there as a foul odor and the skin had been worn through, with the hardware from the surgery showing. The resident was sent to the hospital with an infection and requested not to be sent back to the nursing home. Anyone could certainly understand this resident’s request!
This blog highlights some very high-level deficiencies due to unacceptable facility practices, but anyone should be able to understand the importance that should be placed on the initial development of a plan of care to meet each resident’s individual needs and goals from the time of admission. A smart surveyor only needs to review all the information provided by the transferring institution and identify what a facility might have missed, which, unfortunately, happens when the importance of the development of the BCP is not made a priority by a facility. Don’t let a surveyor beat you out on completing the comprehensive review first.
About the CMS Compliance Group, Inc.
CMS Compliance Group, Inc. is an interdisciplinary compliance and quality improvement consulting firm working with post-acute and long term care providers, including skilled nursing facilities, assisted living, home health agencies and other providers. To learn more about our survey consulting services, click here, or fill out the contact form below if you would like to speak to someone about how we can work together.
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