Feature
What You Need to Know About the
Nursing Home Requirements of
Participation – Phase 3
T
Whereas changes in Phase 1 and
he Centers for Medicare and Medicaid Services (CMS) issued new nursing home
requirements that took effect in November 2016. The changes were the first
comprehensive revision to the regulations since the Omnibus Budget Reconciliation
Act of 1987 (OBRA) nursing home regulations and were so broad in scope that they
were to be phased in over time, with the third and final phase becoming effective
Nov. 28, 2019. The new requirements relate to the increased acuity of nursing home
residents, a need for better behavioral health and an emphasis on person-centered
care. The changes reflect the overall CMS initiatives of reducing unnecessary
hospitalizations, reducing healthcare-associated infections, reducing
Phase 2
the use of antipsychotics and improving behavioral health.
required some policy and procedure
changes, Phase 3 poses some unique
challenges from a policy, educational and
structural perspective.
While November 2019 may seem like a long way off, nursing homes
should start to look at strategies to ensure that they will be fully
compliant by the implementation date. Whereas changes in Phase
1 and Phase 2 required some policy and procedure changes, Phase
3 poses some unique challenges from a policy, educational and
structural perspective.
Among the major components contained in Phase 3 are:
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Ensuring that residents who are trauma survivors receive culturally competent,
trauma-informed care in accordance with professional standards and practice.
Ensuring that licensed nurses have the specific competencies and skill sets to care
for residents’ needs, as identified through assessments and described in the plan
of care.
Ensuring sufficient staffing to provide direct services to residents with the
appropriate competencies and skill sets as part of the facility’s behavioral
health services.
Ensuring an active, engaged and involved governing body.
Ensuring an effective Quality Assurance Performance Improvement (QAPI)
program that identifies and maintains performance improvement data and
activities.
Designating one or more individuals as an Infection Control Preventionist (ICP).
Developing, implementing and maintaining an effective compliance and ethics
program.
Equipping the facility to allow residents to call for staff assistance through
a communication system which relays calls directly to a staff member or a
centralized work area.
Based on the facility assessment, providing training to staff, contract staff and
volunteers.
Addressing in training the following: communication, resident rights, QAPI,
infection control, compliance and ethics and behavioral health.
Many members have used LeadingAge New York ProCare to provide consulting
services in developing policies and training related to Phase 1 and Phase 2.
For Phase 3 issues and concerns, please call 518-867-8383 to make arrangements for
a ProCare consultant to provide direction and guidance tailored specifically to your
organization’s needs.
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Adviser a publication of LeadingAge New York | Fall 2018