New Staff Interviews, Deeper Dive into PBJ Data May Mean More Fines


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Nursing home operators should pay close attention to questions interviewers ask employees about sufficient staffing after the issue was highlighted in updated guidance released this week by the Centers for Medicare & Medicaid Services.

CMS now plans to incorporate staffing figures from the Payroll Based Journal into investigations of potential non-compliance with nurse staffing requirements. Investigators will look for issues such as understaffing, lack of an eight-hour-a-day registered nurse, and lack of 24-hour-a-day registered nurses.

If investigators develop concerns after research and interviews with staff, they will be asked to dig deeper to determine the severity of the non-compliance.

“While the administration may feel the facility has sufficient staff, direct care staff may disagree,” noted Amy Stewart, vice president of education and certification strategy. from the American Association of Post-Acute Care Nursing.

AAPACN suggests that facility leaders in response should review labels F725 (sufficient nursing staff) and F727 (registered nurse coverage) and “pay particular attention to interview questions that interviewers will ask staff about sufficient staffing. “Stewart said. McKnight Long Term Care News Thursday.

She also highlighted the importance of providers submitting their PBJ data on time. She added that updates to Appendix PP ask investigators to cite if PBJ data is missing from CASPER reports.

“Vendors should also be aware that although the PBJ Staffing Data Report uses four or more days without RN coverage, investigators are urged to consider a citation when there is a day without coverage,” warned Stewart. “The same is true if the facility has RN-free days.”

Overall, an additional 98 pages have been added to Annex PP in the updated guidelines.

“Facility managers need to consider these regulatory changes thoroughly because they are important,” Stewart said. “Once they have a better understanding of the changes, they can start planning the next steps.”

She said vendors should start by reviewing change processes and policies; note policies that need to be updated; then plan and train staff for the necessary changes.

“Additionally, be on the lookout for critical element pathway updates and use them to review the efficiency of the institution’s processes,” she advised.

The updated guidance will go into effect Oct. 24, 2022, giving “ample time for investigators and facilities to be trained on this new information,” CMS said.

The new federal guidelines came just a day after Evan Shulman, director of CMS’s nursing home division, told attendees at the 35th National NADONA Conference that updates were forthcoming.

The goal is “to exploit PBJ data in greater depth,” he said. “This is the strongest nursing home staffing data out there. But for the most part, it exists in its own silo.

“Something we’re going to look at is how we can use that hard data and how we can use that to inform investigators about standard investigations so they can better understand the type of personnel that facility typically provides,” he added.

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