What's the best way to prevent Immediate Jeopardy citations?
Patricia Boyer, MSN, NHA, RN
A: We've been assisting facilities in several states with Immediate Jeopardy (IJ) resolutions. One of the big changes we are seeing is that when an IJ situation is cited, multiple tags are affected and so multiple IJs are identified.
It is important to keep up-to-date on what focus your state is looking at so you can monitor your systems and make sure you are in compliance. For example, it appears that Tennessee has a focus on side rails. All facilities there are now reviewing their protocols to ensure compliance.
Another example is a focus on abuse in Kentucky. Facilities in that state should be looking at their investigation and reporting protocols. We have been seeing fines of $7,500 to $10,000 per day for extended periods of time.
In many cases, if the resident had an issue that was identified before and then another incident was identified, the state will go back to the date of the original incident and assess the civil monetary penalty (CMP) from then until the resolution of the Immediate Jeopardy. This has resulted in hundreds of thousands of dollars in CMPs.
What can you do to prevent this result? First, make sure all systems are operating on evidence-based clinical standards of practice. Second, make sure your processes meet all state requirements such as reporting requirements for abuse.
Third, I strongly suggest you consider having a mock survey prior to the start of your survey window. You can have a sister facility complete the review, have your corporate nurse complete the review or, if neither of those two options is available, hire a consultant. You need to have an objective eye look at your systems and make sure you are in compliance.
Please send your payment-related questions to Patricia Boyer at ltcnews@mcknights.com.
