This week on the CMSCG Blog, we are reviewing a Phase 3 tag, F940 Training Requirements – General. When we initially posted our “Ftag of the Week” for F940 back in March 2019, there was limited information about what was actually expected under this regulatory requirement. The revised guidance to surveyors that was published as an advance copy in June 2022 includes additional information regarding the Centers for Medicare & Medicaid Services (CMS) expectation for providers.
As you are likely aware, all facility staff need to receive training on how to interact with residents in a manner that enhances their quality of life and helps them achieve or maintain their highest well-being. Training expectations should be consistent with their roles, so while some staff receive more training, everyone (including students and volunteers) is expected to have a handle on the “basics.” All the required orientation and annual training topics cover those basics, but don’t forget about the areas that are being emphasized in the Phase 3 training requirements.
Surveyors will be looking for staff knowledge and competency during survey now that they have guidance to survey for these regulations. Staff must be able to demonstrate competency in areas covered in the training program, and training records must be maintained which, unfortunately, continues to be a problem for some facilities.
Training Requirements & The Facility Assessment
As we’ve been saying for months now, the Facility Assessment is becoming increasingly important. The guidance to surveyors notes that facilities are expected to determine their training needs based on the Facility Assessment.
Appendix PP (10/04/2022) states that facilities’ training needs will change over time and vary by facility, so CMS has provided flexibility for training requirements. However, there are a lot of “suggestions” that the Agency has included that are likely to be relevant based on your Facility Assessment. These topics include, but are not limited to:
- Cultural competency – this is not a recommendation – it is a regulatory expectation that’s about to get more scrutiny come October 24th
- Substance abuse – this is also not a recommendation – pay attention here – you had better know your resident’s care needs and SUD if applicable
- Trauma-informed Care – This is also something your staff needs to have a understand the concepts of – quickly.
- Advance care planning
- Intellectual disabilities and mental disorders/illnesses
- Working with non-traditional nursing home populations, including younger and middle-aged adults
- Person-centered care
- Specialized rehabilitative therapy
- Quality of Life
- Quality of Care
- Geriatrics and Gerontology concepts
An issue identified under F940 Training Requirements – General would be the result of surveyors identifying that a facility has failed to implement multiple training requirements in the Training Requirements regulatory group (F940-F949).
We all should have been paying attention a few years ago when the initial regulatory revisions were initiated regarding to the need to update and revise our training materials to include care issues that are becoming high profile during a regulatory review. Administrators need to develop a plan for assessing the content and quality of education being provided by Staff Development or an outside training organization that specializes in e-learning. Let’s not forget that those sign-in attendance records may also be invaluable in providing validating evidence that you have provided the necessary training to your staff.