One, Two – With Polls, Three Isn’t Guaranteed – Guest Columns


Angi Livingstone

We are seeing a drastic increase in unfavorable survey results putting operators in precarious authorization situations while waiting for a first, second or third visit. Additionally, we are seeing multiple revisit failures with increased scope/severity.

Chapter 7 of the State Operations Manual (SOM) – Investigation and Application Process for Skilled Nursing Facilities and Nursing Facilities clearly defines the “guideline for certifying compliance based on the seriousness of the non-compliance and the number of visits that have already taken place”.

It also provides guidance on paper reviews and site visits. While some circumstances require “mandatory site visits”, others do not, and compliance can be determined by document review. The SOM includes a clear and specific chart, “Revisit/Date of Compliance Policy,” to guide investigators and facilities on revisit requirements.

Since a third visit is not guaranteed and must be approved by the regional office of the Centers for Medicare & Medicaid Services, it is essential to ensure compliance on the first or second visit. Failure to clear on the second visit puts the facility at serious risk of termination of the vendor agreement and loss of license, as there is no assurance that the third visit will be approved, and the investigation opened/the six-month period is rapidly disappearing.

Our reviews of deficient practices associated with multiple failed revisits and resulting repeated shortcomings have identified that facilities are often cited for the same settlement. However, the actual identified deficient practice is different due to the fact that the facility did not consider the entire regulation and did not take all necessary steps to comply with the entire regulation.

Although the remediation plan should address the corrective actions that will be taken for the resident(s) who have been affected by the identified deficient practice and the resident(s) who may be affected( s) by the same deficient practice, the establishment must comply with all the regulations. Therefore, the investigating agency will validate compliance based on the full regulation and completeness of all regulations, not just the deficient practice identified.

In preparation for a return visit, validate that all components of the POC have been implemented. It is also imperative to validate compliance with the full regulations that have been cited, as well as all regulations. Assess and audit all processes and systems to identify any areas of non-compliance, implement corrective actions, incorporate into QAPI and train staff.

Don’t let the old adage “I can’t see the forest for the trees” cause a failed revisit. Consider an unbiased and objective approach to POC validation through the use of internal organizational resources that are unaware of the establishment/survey and/or third-party results.

Angi Livingston, MHA, BSN, RN, is a Principal Consultant at Formation Healthcare.

The opinions expressed in McKnight Long Term Care News guest submissions are those of the author and not necessarily those of McKnight Long Term Care News or its editors.

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