If you find yourself wondering if you have everything covered ahead of your next survey window, then you're not alone. No one wants a survey or audit to reveal unexpected deficiencies in your work processes resulting in dreaded fines or rushed correction plans. So, to give you peace of mind regarding what surveyors will be looking out for under the phase three enforcement, we've asked our compliance expert, Rebecca DeRousse MBA, MHA, CNHA, to give us her take on the latest guidance to surveyors and what the management of senior care communities should be conscious of when their survey window is approaching.
This article outlines six elements of phase three standards which have been defined in the phase 3 guidance to surveyors. For a more comprehensive overview of what phase three enforcement means for your facility, you can watch our free, on-demand webinar at your convenience.
We all know that as a care community, we are required to protect residents from sources of abuse including from staff, visitors and other residents, and to implement corrective action to prevent future abuse where allegations of abuse have been made. But in terms of compliance, one of the most important actions to take should abuse occur is to alter the care plan of those affected to reflect an informed response to that abuse.
Allegations of abuse must be treated seriously, and the procedures must support a right to file a complaint for retaliation to the state agency. Having retaliation complaint procedures visible to both staff and residents in the form of signage is vital to this.
Your facility is now required to develop and implement written procedures regarding the correct process for reporting disclosures of abuse or criminal suspicions and annually notify any covered individuals of their obligation to follow these procedures. There are also new guidelines on how long after forming a suspicion of abuse you should report it to both the state agency and law enforcement entities.
.png)
If the alleged abuse resulted in serious bodily injury then you must report it within two hours and if it did not result in bodily harm you must report it within 24 hours. Criminal offenses and suspicions of abuse should always be reported immediately where possible, but these are the official standards that you would potentially be penalized for failing to mee.
Here's where Rebecca DeRousse claims the guidance to surveyors gets “a little scary” for nursing facilities.1 Under phase three enforcement, once admitted, residents are entitled to remain in that facility and return to that facility after temporary transfers to an acute care setting unless any of the following special limitations are met:
· If the resident's level of care requirements has changed and the facility can no longer meet their care need or if their care need has de-escalated enough for them to leave
· If the health and safety of other residents would be compromised by a resident's presence
· If their costs are not being met
· If the facility ceases to operate
These are the limited circumstances under which a facility can now initiate a discharge or transfer; therefore it is vital that every admission is carefully considered. Surveyors can investigate transfers and discharges even if an appeal did not occur, so caution and thorough documentation are advised to avoid potential risk to your facility.
Rebecca DeRousse defines culturally competent care as “being respectful and responsive in regard to [a resident's] health beliefs, their practices and their culture.”1
As caregivers, we must be able to effectively care for the needs of those across diverse population groups such as racial, ethnic, religious or social groups in a manner that aligns with the resident's cultural identity. It is best practice for healthcare professionals to ensure care plans reflect the culturally competent care implementations and programs where applicable. Documentation has a crucial role in demonstrating compliance.
If you aren't confident in your ability to provide a secure environment in which residents' cultures, ethnicities and faiths are observed and embraced, then we encourage you to gather the interdisciplinary team to work out what can be done to enable this essential feature of quality care.
The guidance to surveyors defines trauma-informed care as an “essential part of person-centered care” as it aims to individualize each person's care plan based on individual experiences and reactions. Again, any investigation into instances of past trauma and adjustments made in light of those findings should be recorded in that resident's care plan by the appropriate healthcare professionals to demonstrate compliance and competent care planning.
We now fully understand that trauma and symptoms of trauma are interconnected with health conditions and a general state of well-being. Therefore, we must not only be sensitive to the present effects of past trauma but also be proactive in preventing re-traumatization and in identifying individual triggers.
The Substance Abuse andMental Health Services Administration claims that around 70% of US adults have experienced at least one traumatic event in their lives, so trauma-informed care planning must have a vital role in the majority of care plans, not the minority.2
Bed rails and their role in the mitigation of the risk of falls at nighttime has been a “hot topic” for a while in long-term care and although guidelines still differ somewhat by state, it is clear that using bed rails as a go-to fall prevention measure is fundamentally flawed.
Depending on the type of bed rail used, risk of injury from entrapment or falling from a greater height are just two of the reasons why these bed safety rails can be far from safe. The guidance now suggests that a facility must attempt to use every appropriate alternative to any full-length type of bed rail before installing them on the bed frame of hospital beds. "This means that they are considered to be the last resort."1
Rebecca gives us her insight on alternatives to traditional bed rails that could fulfill that requirement.
“What are some alternatives? It could be a roll guard, it could be bumpers, lower beds, and concave mattresses. Accora has a FloorBed which has an adjustable height and width which goes down to 3.9 inches which is very, very low but also it will raise to 31.5 inches to provide nursing care and that is an example of a great alternative for bed rails.”1 – Rebecca DeRousse
Should you decide that there is no alternative to an adult bed rail and that beds like FloorBeds that can take the bed height very low for reduced impact and risks of injury are not appropriate, then you must assess for entrapment, justify this in documentation and obtain informed consent from the resident or their representative before installation.
It's also worth noting that if you are installing any of the types of bed rails that weight capacity and bed types are considered, and proper installation guidelines are observed. In addition, maintenance staff or caregivers must periodically inspect the safety bed rails for signs of wear and assess the condition of the bed safety rail and the fixtures for the safety of seniors in their care.
While these six topics are far from a comprehensive guide to the phase three guidance to surveyors, they are the points that stand out most to us as the new elements not to be overlooked if you want a smooth survey. However, if you're interested in a more thorough introduction to the interpretive guidelines and guidance to surveyors then you can findour on-demand free webinar on readiness for phase three enforcement here.Our compliance expert, Rebecca DeRousse covers training and staffing requirements, binding arbitration agreements, QAPI guidelines and much more.
Watch it anytime and if you find it insightful and informative then please feel free to share it with a colleague.
Sources
1 - https://us.accora.care/webinars/readiness-for-phase-3-enforcement
Once thought to be essential tools in the battle against falls, bed rails were traditionally installed on hospital beds as a safety feature for fall-risk patients. Now it is largely thought that the safety concerns outweigh the possible benefits of bed rails which is why full safety rails are a last resort fall intervention. However, many healthcare professionals still assess for assist bars and levers to aid patients with mobility issues to get to a standing position from the bed and to assist transfers back into bed. These short handrails or grips are commonly used types of bed rails for those with limited mobility and to assist with independent and assisted transfers and are generally considered to be safe options for seniors.
Assist bars are compatible with Accora FloorBeds and in addition to the high safety mat which creates an even plane sleeping surface, can be a rail-free, nighttime, fall prevention system to give caregivers and residents true peace of mind.
Bed safety rails were once considered essential items in nursing homes. The primary benefit of hospital bed rails may be the physical barrier that they present to prevent seniors from falling out of bed. Some older adults may feel safer and therefore experience a more restful sleep with that additional layer of safety between them and the floor and sense of security. However, Bed rails have been associated with an increased risk of accidents in terms of entrapment and resulting injuries, and in some cases, death caused by asphyxiation.
In addition, where cognitive impairment is a consideration factor then so-called "bed safety rails" may be especially inappropriate because they'll be at a greater risk of impact and injury from a fall if they try to climb over the rail. This means their risk of falls with injury is greater than if they fell from the bed frame. Therefore, best practices and CMS guidance demand that adult bed rails are only implemented as a last resort and all other fall interventions should be assessed first.
Ultra-low beds can be a suitable alternative to senior bed rails. Ones that go to floor level can significantly reduce the risk of injury during the night. Additionally, bed sizes may have a part to play. During our adult lives most people are used to sleeping in a double bed or bigger. Therefore, trying to learn how to situate themselves in a single bed again suddenly can be disorienting and can potentially increase fall risk.
The Empresa FloorBed from Accora has an optional width-adjustment kit that increases the width of the bed and the Contesa FloorBed is available to purchase in two width sizes for comfort and enhanced safety against accidental falls.
Bed assist rails, while not a direct alternative, are often considered to be safer than full-length bed rails because they are an enablement measure rather than a restraint. They also do not impede caregiver access like standard bed rails may.
{{widget-brochure}}
.jpg)
