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Centers for Medicare & Medicaid Services (CMS)
The Centers for Medicare & Medicaid Services (CMS) recently released a full listing of 2567 Statement of Deficiencies information compiled through November 2018. This provides a full year of data from state surveys conducted under the revised survey process that is based on the regulations that became effective November 28, 2017. It is noteworthy that three of the top ten most cited deficiencies are #5 – F755 Pharmacy Services, #6 – F761 Labeling and Storage of Drugs and Biologicals, and #10 – F758 Psychotropic Medications. The #1 most cited F-Tag is F880 – Infection Control, which can have significant connection to medication administration practices.
PADONA recommends continuing the close relationship that you have with your pharmacy services provider and consultant pharmacist. Communicate this CMS information and work together to be proactive in preventing these deficiencies in your facility.
Nursing Care Facility Recertification Survey Forms
Attached are forms that are required to be completed and given to the State Agency during recertification surveys. They are being posted in a format that can be saved and provided to the survey team upon entrance.
Please note the Entrance Conference Worksheet for NHA is being provided in addition to a State Entrance Conference Checklist and a SNF Beneficiary Protection Notification form.
Please note the Matrix with Instructions.pdf (CMS-802 (11/2018)) must be used instead of earlier versions.
MDS Teleconference CD Request Form
On January 10, 2019, a training teleconference titled “Updates for a Rapidly Changing MDS World” was presented. To receive a compact disc (CD) of this teleconference, please complete and fax the attached form to Myers and Stauffer at 717-541-1206. The associated handouts will be included on the CD.
MDS coding of item S9085C
Please note that AmeriHealth Caritas (Southwest) and Keystone First (Southeast) are the same CHC plan with differing names.
Both should be coded a “01” at S9085C on the MDS.
Contact List for Directed In-Service Providers
Attached is the contact information for persons who have communicated an interest to provide directed in-service training.
When the remedy of Directed In-Service training is imposed, the facility will be responsible for the procurement of services from an appropriate resource, and the facility will submit a copy of the proposed training program to the supervisor at the State Survey Agency for approval within the same 10-day period that is required for submitting the plan of correction.
Nurse Aide Registry Annotation List
Attached, for your information, is a listing of all nurse aides who have had substantiated findings of resident abuse, neglect or misappropriation of resident property entered on the Pennsylvania Nurse Aide Registry as of January 4, 2019. The Nurse Aides names that have been added since the last issue are bolded.
Verification of a nurse aide’s status must still be done before hiring to verify eligibility for employment in a nursing care facility. An individual nurse aide’s status may be verified by accessing the twenty-four hour online access to the registry via the Department of Health website at www.health.pa.gov/ . Once this site is accessed, click on “Healthcare Facilities” at top of page and next select “Registries” and “Nurse Aides”. Next click on “Nurse Aide Registry On-line”. Choose “Pennsylvania Department of Health” under the program once on the Pearson Vue Pulse portal page and use “Registry Search”.
If you would like additional information or have any questions, please feel free to contact Division of Nursing Care Facility staff at 717-787-1816.
Updated Nondiscrimination Notice
Please see the attached Nondiscrimination Notice for facilities operated in accordance with the regulations of the Pennsylvania Department of Health.
Five Star Updates
Updated Full Text of Statement of Deficiencies
https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/FSQRS.html
Updated Cut Points
https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/Downloads/cutpointstable.pdf
Surveyor Training Modules
RAI Spotlight Newsletter
Attached is the latest issue of the RAI Spotlight newsletter. Included are details about the next scheduled MDS teleconference.
The RAI Spotlight newsletter is published at the end of February, May, August and November. The four most recent issues are posted in the Bulletins section of the Nursing Facility Report Portal (NFRP). If you are interested in an older issue, please contact the Myers and Stauffer help desk at 717-541-5809. A generic form to request a CD of any teleconference may be found in the Resources section of the NFRP.
Revised Resident Data Reporting Manual
The Department of Human Services (DHS) published changes to the Manual.
SNF Quality Reporting Provider Preview Reports Are Now Available
Skilled Nursing Facility Provider Preview Reports have been updated and are now available. Providers have until Nov. 30, 2018 to review their performance data on quality measures based on Quarter 2 -2017 to Quarter 1 – 2018 data, prior to the Jan. 2019 Nursing Home Compare site refresh, during which this data will be publicly displayed. Corrections to the underlying data will not be permitted during this time. However, providers can request a CMS review during the preview period if they believe their data scores displayed are inaccurate.
More information can be accessed:
Skilled Nursing Facility Quality Reporting Program
Fact Sheet on Transitions for New Quality Measures and Data Elements Effective October 1, 2018
FACT Sheet:
Website Link:
Alzheimer’s Association and how to join
Attached is a brochure with details about the Alzheimer's Association and how to join. Also attached is information on their curriculum, which has been taught successfully in a variety of care settings for over 20 years. It provides 13 hours of vetted training that may help decrease difficult behaviors, reduce the use of psychotropic medications, help staff gain insight into fall prevention and improve communication between staff and persons living with dementia. This trainer habilitation curriculum also fulfills the training requirements to become a Certified Dementia Practitioner.
Medicare Advantage Appeal Outcomes and Audit Findings Raise Concerns About Service and Payment Denials (OEI-09-16-00410)
What OIG Found
When beneficiaries and providers appealed preauthorization and payment denials, Medicare Advantage Organizations (MAOs) overturned 75 percent of their own denials during 2014–16, overturning approximately 216,000 denials each year. During the same period, independent reviewers at higher levels of the appeals process overturned additional denials in favor of beneficiaries and providers. The high number of overturned denials raises concerns that some Medicare Advantage beneficiaries and providers were initially denied services and payments that should have been provided. This is especially concerning because beneficiaries and providers rarely used the appeals process, which is designed to ensure access to care and payment. During 2014-16, beneficiaries and providers appealed only 1 percent of denials to the first level of appeal.
Centers for Medicare & Medicaid Services (CMS) audits highlight widespread and persistent MAO performance problems related to denials of care and payment. For example, in 2015, CMS cited 56 percent of audited contracts for making inappropriate denials. CMS also cited 45 percent of contracts for sending denial letters with incomplete or incorrect information, which may inhibit beneficiaries’ and providers’ ability to file a successful appeal. In response to these audit findings, CMS took enforcement actions against MAOs, including issuing penalties and imposing sanctions. Because CMS continues to see the same types of violations in its audits of different MAOs every year, however, more action is needed to address these critical issues. Read the full report here. https://oig.hhs.gov/oei/reports/oei-09-16-00410.pdf
RAI Manual Errata File
An RAI User’s Manual Errata file has been posted to the CMS MDS 3.0 RAI Manual webpage at: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursinghomeQualityInits/MDS30RAIManual.html
The Errata file, titled MDS 3.0 RAI User’s Manual (v1.16R) Errata (v1) October 1, 2018, is located in the Downloads section of the webpage and contains the RAI Manual Change Table and associated replacement pages.
Revisions include:
- Chapter 3, Section J, Item J2000 Prior Surgery, amended criteria for Major Surgery. Specifically, the removal of the general anesthesia criterion.
- The examples for coding J2000 have been corrected to remove the criteria of general anesthesia
- Updated manual pages are marked with the footer “October 2018 (R)”
Providers who use a print version the RAI User’s Manual should print the manual replacement pages and incorporate the replacement pages into the printed manual. A revised manual has not been posted, just the Errata
Forms that are required to be completed and given to the State Agency during recertification surveys
Attached are forms that are required to be completed and given to the State Agency during recertification surveys. They are being posted in a format that can be saved and provided to the survey team upon entrance. Please note the Entrance Conference Worksheet for NHA is being provided in addition to a State Entrance Conference Checklist and a SNF Beneficiary Protection Notification form.
Entrance Conference Worksheet for NHA.pdf
SNF Beneficiary Protection Notification.doc
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Candace McMullen
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