Proposed LTC Regs: The Facility Assessment

In the newly proposed “Medicare and Medicaid Programs: Reform of Requirements for Long-Term Care Facilities,” there is one element that so many other regulations depend on – the facility assessment. Under the new regulations, nursing facilities would be required to conduct a facility assessment, which would review the capabilities of the facility and the resident population. The assessment of the facility population would take into account resident needs based on acuity, diagnosis and the individualized, comprehensive care plan.

The facility assessment, which would be under the Administration regulatory category, would include the following information to help facilities determine the resources that they would need to care for residents on a daily basis as well as during emergency situations.

  • Resident statistics, including number of residents, facility capacity, care required for specific diseases/conditions/disabilities, and overall acuity of resident population
  • Required staff competencies to provide the necessary level of care
  • Information on personnel, including employees, contracted staff and volunteers with their education/training and resident care competencies included
  • The physical environment, equipment and services that are required to provide the necessary level of care
  • The resources of facility, including buildings, other physical structures, transportation, and equipment
  • Listing of the services provided, including physical therapy, pharmacy and any types of rehabilitation
  • Information on factors that could potentially affect the care being provided, including ethnic, cultural and religious factors
  • Contracts/third-party agreements for services/equipment during daily operations as well as emergency operations
  • Health information technology information, including EMRs and capabilities for electronic sharing of information

This assessment provides the foundation for several regulatory areas, including:

  • Staffing – the information in the facility assessment would help facilities determine what “sufficient” staffing is, including ensuring that staff have the necessary skills and competencies to provide the level of care that the residents need.
  • Reducing unnecessary use of antipsychotic medications – the facility’s comprehensive assessment provides information on the physical characteristics of the facility, the resident population, the knowledge and competencies of the staff, and the necessary support to be provided – including additional training and/or staff – required to care for residents and reduce the use of these medications with better training and staffing.
  • Prevention of healthcare associated infections (HAIs) – The facility-specific assessment provides insight to the facility on its residents’ medical needs and potentially increased susceptibility to HAIs in order to develop a comprehensive prevention plan. This is just a part of the much larger focus by CMS on Infection Control.
  • Food and Nutrition – By incorporating the facility assessment into the individual assessments, CMS believes that facilities will be able to offer residents more meaningful choices in their diets that meet nutritional requirements and are appetizing to each individual resident.

The facility assessment would require an annual update, as it provides so much critical information to assist facilities with taking a person-centered, competency-based approach to caring for their residents. Want to know more about person-centered care and competency-based staffing? Keep checking the CMSCG Blog for more information. If you missed our overview of the proposed LTC regulations, check them out here.

CMS Compliance Group has significant experience assisting nursing facilities with assessing their capabilities for proper staffing. To learn more about how CSMCG can help your facility, contact us.

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