Although we usually pause the CMSCG “Ftag of the Week” blog series for the summer, that’s not in the cards this year now that we have updated guidance for the Requirements of Participation effective October 24, 2022. The RoPs have greatly expanded requirements and guidance related to behavioral health, so this week we’re looking at F949 Behavioral Health Training. This is likely an area that will take some focus and time to roll out in your facilities with success.
F949 requires that facilities develop, implement and maintain an effective behavioral health training program for all staff (direct care staff, indirect care staff, contract staff and volunteers, as appropriate to their roles). The training must be based on what has been identified in the Facility Assessment (F838) and consistent with F-tag F740 Behavioral Health Services (up next on the “Ftag of the Week”).
What Needs to Be Included in Your Training
The Facility Assessment is the main driver of the training curriculum that needs to be in place, so if you haven’t reviewed yours within the past year, this is a good time to review and revise it. Behavioral health training needs to address the skills and competencies that your staff need to provide person-centered care and services. These include, but are not limited to:
- Being able to provide care for residents with have been diagnosed with a mental, psychosocial or substance abuse disorder (SUD)
- Providing care for residents with a history of trauma and/or Post-Traumatic Stress Disorder (PTSD) or other behavioral health condition (don’t forget about F699 Trauma-Informed Care)
- Caring for residents who are diagnosed with dementia (F744 Treatment/ Service for Dementia)
- Implementing nonpharmacological, individualized approaches to care
- Providing activities for residents that promote their engagement
- Developing meaningful relationships with residents
- Providing an environment and atmosphere that is conducive to the mental and psychosocial well-being of residents, including those with individualized behavioral health needs noted above
During survey, the surveyors will be observing to see if the behavioral health needs of your residents are being met. If not, they will conduct interviews and review your training records to determine if staff are able to demonstrate the necessary skills to care for residents with identified behavioral health needs. The surveyors are also guided to determine if staff can explain the behavioral health training concepts that they have learned. This means it’s time to take a hard look at the education and training being provided to your staff as it relates to everything from dementia care to serious mental illness. If you have behavioral health conditions listed in your Facility Assessment as relevant for your resident population, then it is more important than ever that you ensure your staff have the skills and tools necessary to provide high quality of care and services to meet these unique needs. A last thought – have you even included the mental health diagnoses of residents whom you routinely provide care for in your Facility Assessment?