The Centers for Medicare & Medicaid Services (CMS) has issued its first enforcement guidance for the minimum staffing mandate, which will allow surveyors to assess nursing home compliance using facility assessments. However, we are hearing from our clients that more clarity is needed regarding some of the provision’s key points and we’re here to help!
What are facility assessments and how will they impact nursing homes?
Facility assessments are essentially blueprints for how a nursing home allocates resources to meet resident needs. Under the new guidelines, these assessments must be comprehensive and data-driven, which means considering:
- Resident needs: including types of illnesses, physical and mental health conditions, cognitive abilities, and overall acuity of the resident population.
- Staffing levels and skills: The assessment should determine the specific competencies and skill sets required by staff to provide proper care for the specific resident population.
- Resources: This includes everything from physical plant considerations (equipment, environment) to resident services (food, activities) and even electronic health record systems.
What are the challenges and how can facilities prepare?
Like the new staffing mandate, this focus on data-driven assessments aims to improve resident care but it may pose challenges, especially for smaller facilities.
Here's what nursing homes can do to prepare:
- Review and update existing facility assessments: Don't wait until August (2024). Start familiarizing yourself with the new requirements and revise your assessments accordingly.
- Gather resident data: Collect and analyze resident information to understand their specific needs.
- Focus on recruitment and retention: The assessment should inform strategies for attracting and keeping qualified direct care staff.
Additional details to consider
- The deadline for nursing homes to comply with the new facility assessment requirements is August 8th, 2024.
- CMS has not yet released a template for how to do the facility assessment, but they say one is forthcoming.
- The enforcement approach and penalties for non-compliance have not yet been determined
What's next?
For many facilities, these assessments are the first real-world impact of the new nursing home staffing rule. CMS has made it clear that compliance with the assessment requirements is crucial and facilities must demonstrate adequate staffing based on resident needs.
While this change in the assessment process may cause challenges, this is designed as a significant step towards ensuring adequate staffing levels in nursing homes. By focusing on data and resident needs, CMS aims to improve the overall quality of care for our elderly population.
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