F-Tag revisions: Have you prepared?
At the end of October, the release of the 2015 OIG Work Plan for skilled nursing facilities focused on Medicare Part A billing, questionable billing patterns for Part B, survey agency verification of deficiency corrections and SNF preventable hospital readmissions.
But there's another new twist for SNF leaders that may have been lost: CMS updated survey guidance and interpretive guidance for 20 F-Tags that went into effect Nov. 26, 2014!
Per the CMS memo, surveyors have been trained to increase their investigative processes during onsite survey activities, including advanced directives, advanced care planning, dementia care, restraints, falls, accident prevention, nasogastric tubes, antipsychotic medications and more.
The 226-page memo includes clarifications, revisions, scope and severity, and guidance to the Survey & Certification memoranda for FY 2013-2014.
While providers received individual updates during the past couple of years, CMS has issued additional revisions and surveyor guidance to more than 20 F-Tags.
The F-Tags in this memorandum include:
- F155 - Advanced Directive/Advanced Care Planning
- F161 - Assurance of Financial Security - Surety Bonds
- F202 - Documentation related to transfer/discharge
- F208 - Admissions Policy (fees for Medicaid-eligible residents)
- F222 - Restraints and Falls
- F278 - Accuracy of Assessments and Electronic Signatures
- F281 - Professional Standards (policies and procedures)
- F286 - Assessments and Records (state and local law)
- F309 - Dementia (detailed changes) \
- F321 - Naso-Gastric Tubes (assessment, psychosocial, resident rights)
- F322 - Naso-Gastric Tubes (use, management, risks)
- F329 - Unnecessary Drugs (dementia, new guidance per condition, monitoring)
- F332 and F333 - Medication Errors (error rate, dietary supplements and more)
- F371 - Sanitary Conditions (Food and Drug Code and CDC updates, gardens)
- F388 - Physician Visits (NPP, CNS, PA criteria and face-to-face visits)
- F390 - Physician Delegation (Interpretive Guidance updates)
- F425 - Pharmacy Services (medication administration, foreign acquired medications, enteral)
- F428 - Drug Regimen Review (MRR updates)
- F431 - Pharmacy Consultant (missing medications, drug diversion, DEA updates)
- F441 - Infection Control (CDC updates, clean, single-use disposable equipment and more)
- F492 - Professional Standards (accepted professional standards, evidenced based and more)
- F514 - Clinical Records (Electronic Health Records, Electronic Signatures, HIPAA)
- F516 - Resident Identifiable Information (Electronic Health Records, HIPAA)
What should leaders know about managing compliance for these standards?
First, put together a regulatory compliance PIP (Performance Improvement Plan team) comprised of employees from all departments at all levels. Second, take each of the updated interpretive guideline and compare with your current policies, procedures and systems to determine necessary updates. Third, have the PIP team develop an action plan to include:
- System changes and updates.
- Staff education as indicated.
- Auditing processes to report to your QAPI Committee.
Lisa Thomson is the chief marketing and strategy officer at Pathway Health.