This week’s “Ftag of the Week” on the CMSCG Blog is one that providers should be reviewing in detail, F741 Sufficient/Competent Staff – Behavioral Health Needs. We reviewed F725 Sufficient Nursing Staff in a prior blog post, but the requirements at F741 specifically relate to having sufficient staff to competently care for residents’ behavioral health needs.
While many facilities likely provide care and services for residents living with dementia or some mental health diagnoses, the expectation for the care being provided for those residents has been expanded with the revised guidance. Additionally, the regulation includes residents with Serious Mental Illnesses (SMI), Substance Use Disorders (SUDs), and those residents who have survived trauma. The guidance to surveyors significantly emphasizes meeting residents’ behavioral needs throughout the regulatory requirements, and F741 provides even more insight into the regulators’ expectations of your staff’s knowledge and performance. It seems that the provision of “skilled” care now includes ensuring that your staff can competently care for residents with mental and psychosocial disorders as well as those with SUDs – not exactly the same as caring for a short-term resident who had a hip replacement. The expectation has truly been elevated to ensuring that the “whole” person is looked at – physical, mental and psychosocial – to ensure the resident can attain/maintain his/her highest practicable well being in a safe environment.
Sufficient Staff – Behavioral Health Needs
F741 requires that a nursing home has sufficient direct care staff to provide nursing and related services to assure resident safety and the provision of care in accordance with each resident’s plan of care, which is based on their assessments. The facility must have sufficient direct care staff, including CNAs and LPNs, with knowledge of behavioral health care and services to meet resident needs in accordance with their plan of care. This means staff know the resident and his/her plan of care, as well as the appropriate interventions that need to be attempted for that resident.
If a surveyor identifies issues related to a resident’s behavioral health needs, then a deficiency under F741 may be appropriate if the issue can be linked to an inadequate number of staff to meet resident needs.
How many staff have you dedicated to 1:1 assignments for residents with “unmanageable” behaviors that put other residents at risk? Do you even have enough staff in the building each shift to carry out all of those assignments? If not, then what is a surveyor going to think when a resident on 1:1 manages to sexually assault another resident even though staff should have been monitoring them? If you have many residents who unsafely wander, do you have an adequate number of staff to keep all the residents on a particular unit supervised and safe? What about residents who have drug-seeking behaviors who may attempt to bring and use drugs into the facility or get them from visitors? How will you ensure sufficient staff are available to monitor and keep residents safe? It’s a lot to think about, especially given that there is a nationwide staffing shortage in our industry.
Don’t Forget About the Facility Assessment
The Facility Assessment is a driver in determining the “sufficiency” of staffing, and needs to consider the census, acuity and diagnoses of the resident population. The “diagnoses” part of that sentence is where providers need to focus when they are reviewing their Facility Assessment for content and accuracy. While you are at it, check out your staffing plan by unit. What kind of activities are being provided to residents with mental health diagnoses or younger residents with a history of substance use? Do you have the appropriate number of knowledgeable and trained staff to oversee these activities in addition to carrying out the rest of the Therapeutic Rec calendar?
While the Facility Assessment sets out the appropriate number of staff to meet the residents’ needs, another important section of that assessment is to determine the necessary competencies and skill sets that staff need to care for your residents competently. We’ll look at competencies in our next post. In the meantime, you can review our “Ftag of the Week” blog series for F740 Behavioral Health Services and our recent post about F949 Behavioral Health Training to see where you’re at against the regulatory expectations.
About CMS Compliance Group, Inc.
CMS Compliance Group, Inc. is a regulatory compliance and quality improvement consulting firm with extensive experience servicing post-acute and long term care facilities and agencies. With the idea of continuous quality improvement in mind, CMS Compliance Group’s interdisciplinary team provides a unique approach to client service, ensuring that all departments can achieve and maintain compliance while improving quality of care. To discuss how we can work together, please call 631.692.4422.
