Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare
Today – November 22, 2019 – CMS posted QSO-20-03-NH with the same title as this blog. There are 4 very important updates and initiatives identified in this notification:
- Phase 3 (RoP) Interpretive Guidance
- Arbitration Agreements
- Actions to Improve Infection Prevention and Control in LTC Facilities
- Release of Toolkit 3, “Guide to Improving Nursing Home Employee Satisfaction”
This is a QSO that is definitely a must-read!
Providers have been waiting for the posting of Appendix PP for months now, specifically guidance for the Phase 3 Requirements of Participation which were slated to be implemented on Thanksgiving this year. The QSO notification provides this statement (bolding added by me): “CMS will be releasing updated Interpretive Guidance and training for the Requirements for Participation for Long-Term Care (LTC) Facilities. However, this guidance will not be released by the November 28, 2019 implementation date of the regulations. We will be releasing the guidance in the second quarter of calendar year 2020, along with information on training and implementing related changes to The Long Term Care Survey Process (LTCSP). While the regulations will be effective, our ability to survey for compliance with these requirements will be limited until the Interpretive Guidance is released.”
“On July 18, 2019, the Department of Health and Human Services (HHS) published a final rule establishing requirements related to the use of binding arbitration agreements. This final rule amends the requirements that Long-Term Care (LTC) facilities must meet to participate with Medicare and Medicaid. The final rule can be found at: https://www.govinfo.gov/content/pkg/FR-2019-07-18/pdf/2019-14945.pdf.”
Pages 2 and 3 of this 22-page QSO are devoted to resources for improving infection prevention and control in LTC facilities. There you’ll find many hyperlinks to guide you to these resources. In addition, “CMS has created a training titled, “Development of an Antibiotic Stewardship Program for Nursing Home Providers” to support compliance with the requirements for an ASP and to improve appropriate antibiotic usage. The training and a supplemental 2-page listing of ASP resources for nursing homes are available and can be accessed by providers and surveyors at the Integrated Surveyor Training website: https://surveyortraining.cms.hhs.gov. This training will be available starting December 2nd, 2019. Completion of the training does not automatically deem a provider compliant. This training supports compliance, but providers must still meet all components of the antibiotic stewardship requirements.
CMS has also updated the “Nursing Home Infection Control Worksheet” (ICWS) in collaboration with the CDC. “The nursing home ICWS is a voluntary self-assessment tool for facilities to use to improve infection control and prevention. This most recent revision includes questions about facility water management efforts to reduce the risks to residents of Legionella infections. This tool will be available on December 2nd, 2019 on the CMS Integrated Surveyor Training Website: https://surveyortraining.cms.hhs.gov. In this QSO, you’ll also find this 18-page LTC Facility Self-Assessment Infection Control Worksheet/Tool. “It comprises both regulatory requirements and best practices for infection prevention and control. A facility that uses this ICWS will identify gaps in practice and have a “roadmap” that can lead to an improved infection prevention and control program.” This is one of the best provider tools I’ve seen CMS release in a very long time! It includes the following domains:
- Infection Control program infrastructure and Infection Preventionist
- Infection Preventionist relationship to Quality Assurance Committee
- Infection surveillance and outbreak response
- Influenza and pneumococcal immunization
- Linen management
- Infection prevention during transitions of care
- Water Management Program
Be sure to share these resources and the training opportunities with your Infection Preventionist and all staff involved in infection prevention and control (aka – all of your staff!).
Lastly, “CMS is announcing the release of Toolkit 3 – Guide to Improving Nursing Home Employee Satisfaction. This Guide is a repository of evidence-based approaches, solutions and interventions to address challenging areas discovered through the Nursing Home Employee Satisfaction Survey (Toolkit 2). We believe these toolkits will help facilities improve their staff’s competency and reduce turnover, which support improved resident health and safety. Toolkits 1, 2, and 3 are available for free at the CMPRP website at: https://www.cms.gov/Medicare/Provider-Enrollment-andCertification/SurveyCertificationGenInfo/LTC-CMP-Reinvestment.html.”