Ask The Payment Expert about ... Phase 2 of the Requirements of Participation

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Patricia Boyer,  MSM, NHA, RN  Director of Clinical Services,  Wipfli LLP
Patricia Boyer, MSM, NHA, RN Director of Clinical Services, Wipfli LLP

When does Phase 2 of the Requirements of Participation start and should we be concerned? 

Phase 2 of the Requirements of Participation goes into effect Nov. 28. Phase 1 was initiated a year earlier.

Many facilities across the country feel they have been scrutinized differently this year based on those requirements. The main focal issue with Phase 1 seems to be the issue of person-centered care. 

The main way to find out if you have implemented person-centered care is to ask your residents. Use the choices that are identified in Section F of the MDS and the resident interview guides that are part of the Quality Indicator Survey process. 

The answers to those interview questions can be very revealing. Use that information to evaluate your practices through your Quality Assurance Performance Improvement. Phase 2 will take that a step further with the Facility Assessment, which means that you need to gauge your facility to see if you are providing care according to the individualized needs of your residents.

Another change you need to be aware of is the need to have a baseline care plan within 48 hours. This baseline assessment must give direction in providing effective person-centered care and meeting professional standards of care. 

Also in Phase 2, you must share your QAPI plan with surveyors. Without a doubt, these new requirements are the focus of surveyors. We should see a new survey process this summer to be implemented this October. 

The new process will incorporate components of the traditional and quality indicator processes. That is not surprising, as the tools that are in place for the QI survey are focused on person-centered care. Also, the clinical pathways evaluate how you are meeting professional standards of care.

Please send your payment-related questions to Patricia Boyer at ltcnews@mcknights.com.