It shouldn’t be a shock to know that, beginning November 28, 2019, facilities will be expected to implement Phase 3 of the most extensive reform ever made to the Requirements of Participation (“RoP”).
Training Requirements comprise a significant part of Phase 3, including the implementation of an “effective training program.” The facility is responsible for determining the amount and types of training necessary, both for specific topics as indicated in the regulations, as well as topics that are unique to each facility based on the facility assessment. As of the writing of this article, the Guidance to Surveyors is not yet released for the training regulations, but that does not preclude facilities from planning and even implementing a preliminary training program.
Before taking any steps to operationalize the new regulations, first determine what assets the facility already has in place for training. Consider these questions:
- When is training offered the facility?
- How are topics identified?
- Who provides the training?
- Are outcomes measured?
- Is ongoing mentorship provided to help staff be successful in applying the new information?
Also, review the facility policies on training. As you develop the training program, be sure to update your policies accordingly. Train staff on how to operationalize the policies. The facility may want to create a team to engage in a Process Improvement Project (described in QAPI materials as a Performance Improvement Project) around training and the Phase 3 requirements.
The expectation of implementing a formal training program may seem daunting for some facilities. Everyone struggles with time and money being limited, among other challenges. Consider collaborating with other community stakeholders such as hospitals, home health companies, hospices, and social services agencies to pool resources. A joint training session on a topic that serves all settings not only benefits staff, but it increases collegiality and teamwork.
Identify training topics
As indicated in F940 Training Requirements, it states “A facility must have an effective training program for all new and existing staff; individuals providing services under a contractual arrangement; and volunteers, consistent with their expected roles.” The specific topics that must be included in the training are: Communication, Resident’s Rights and Facility Responsibilities, Quality Assurance and Performance Improvement, Infection Control, Compliance and Ethics, and Behavioral Health.
Abuse, neglect and exploitation (F943) and required in-service training for nurse aids (F947) were included in the Phase 2 RoP revision. While training staff on abuse and neglect is not new, there are additions to the abuse and neglect regulations that must be addressed. Those changes include training on person-centered thinking, planning and practice skills that contribute to a culture of prevention; identifying and preventing behavior that constitutes abuse; identifying physical or psychosocial indicators of abuse; and, education around dementia care, and abuse prevention.
Also note that the Guidance to Surveyors for F-948 Required training of feeding assistants was expanded to include a series of questions, “probes,” that the surveyor can use to help investigate concerns about training for feeding assistants.
The Facility Assessment (F838) is an excellent starting point to identify areas of training and is specifically referenced in the Guidance to Surveyors in F943. But, do not make the mistake that just because an area is not identified on the facility assessment that it doesn’t warrant training. For example, if the facility admits a resident with Huntington’s Disease, staff needs to be cognizant of the diagnosis, prognosis, medication regimen and potential behavioral manifestations unique to this particular diagnosis.
Refer again to the Guidance to Surveyors in F943, specifically the list of questions or “Probes.” This is an excellent source of information that can help the facility investigate, assess and even develop more robust programming around resident care and staff development. Consider the questions:
- “Was staff observed working with residents in a manner that indicates a training need?”
- “Did interviews with residents and/or resident representatives indicate any areas where training was needed?”
- “What type of training do the staff report receiving about the concern identified by the surveyor?”
- “What process does the facility have to encourage staff to express concerns and request training in challenging situations? How does the facility respond to staff’s concerns and requests?”
- “How does the facility assess staff to determine if the training has been effective?”
A key to developing a fantastic training program is a facility culture that encourages and welcomes staff engagement, especially to acknowledge, and ask for, additional training. Whether it’s a wound care protocol, communicating with an angry family member, care planning for a justice-involved individual, upholding residents’ rights, preventing resident-on-resident altercations, the medication regime for an unfamiliar diagnosis, or intervening with sexually inappropriate behavior, make training and education an integral part of the facility culture.
Get staff input about areas they would like to improve, and what they would like to learn more about! Make a list of topics and ask staff to prioritize them. When people are engaged in the learning process, the information is more meaningful and a better use of everyone’s time.
Develop training sessions
What does training mean? It seems rather simple; training teaches someone how a job is supposed to be done. Everyone needs training to learn the skills to do a job. Training should be uniform and leave little doubt about what is required to perform the job. (Neave) Inservices are a common way to train staff in nursing homes. They seem to be the “go to” strategy for imparting new information or reinforcing “old” information. Usually in an inservice, staff are “talked at” and not actively involved in the discussion. Have you ever wondered how effective this type of training really is?
Receiving instruction on how to do something is relatively easy. Operationalizing that knowledge, especially if it is a stressful situation, is much more difficult. Imagine a nurse aide face-to-face with a resident who is demanding to smoke outside of established smoking times. What exactly does that staff member do, and say, in that situation? How do they respond if the resident becomes belligerent and threatening? In other words, what do you expect staff to do with the information provided in any inservice? How do they take it from a meeting and use it? Think about the processes of learning and applying the knowledge. Unfortunately, staff are usually told what to do, just not how to do it when in the moment.
Developing a great training program that makes learning fun and interesting takes effort and time. It’s worth it! Not only will staff be more engaged, residents will receive better care and the facility will perform better on surveys.
Paige Hector, LMSW, is a Clinical Educator at Paige Ahead Healthcare Education & Consulting LLC.