It's not just you: Everything's hard about Phase 2 Requirements of Participation

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James M. Berklan
James M. Berklan

An interesting phenomena occurred Tuesday when we asked providers for the toughest part of complying with Phase 2 provisions of the Requirements of Participation. There were five options given and the hundreds of respondents nearly couldn't make up their collective mind.

Internally, it was widely expected that infection control/antibiotic stewardship would be the clear (dis)favorite. It did lead all vote-getters with just over 25% of the electorate.

But the other four were unexpectedly close — to the leader and to one another.

Facility assessment was runner-up at 20.2%, closely followed by QAPI (19.3%), antipsychotics (18.9%) and baseline care plans (15%).

That is not what one can fairly call unanimity, which means that when the Centers for Medicare & Medicaid Services designed their massive overhaul of regulations, it got something right. The agency clearly found a variety of gaps in providers' preparedness. 

We can reconvene another day to debate whether all of these areas need extra vigilance or more complicated regulatory requirements. But it is beyond interesting that such large proportions of providers found each of these areas their biggest challenge to attain compliance.

The good news is that overall, providers seem to be getting on board pretty well with Phase 2 compliance. There's still work to be done, as Tuesday afternoon's webinar title correctly noted, but attendees there received plenty of guidance on how to cross the finish line with heads held high. (The webinar can be listened to in archive through this story and link at the bottom.)

In brief, you need to have strong leadership and make sure your practices follow whatever policies and procedures you come up with, said featured speaker Chris Murphy, CPA, a partner with consultancy BKD LLC.

And don't forget about getting to know the State Operations Manual, he added. Such sage advice has been around for years, but now, more than ever, it can either help you or hurt you. Which it will be depends mostly on how dedicated you are to reading and digesting it.

Coincidentally — and therefore all the more telling — Murphy isn't the only expert to highlight the importance of the SOM in the last eight days for a McKnight's presentation. 

Check out Leslie Mahoney's, RN, BSN, excellent guest column, "A former surveyor tells THE key to good star ratings," which emphasizes the importance of the SOM. It rightfully attracted droves of readers. Mahoney is absolutely bewildered that providers could neglect giving the SOM their full attention.

Then again, as Tuesday's little polling exercise showed, there are numerous new regulatory demands conflicting providers and vying for their full attention, all of them important in their own way.

Follow Editor James M. Berklan @JimBerklan.

Daily Editors' Notes

McKnight's Daily Editors' Notes features commentary on the latest in long-term care news and issues. Entries are written by Editorial Director John O'Connor, Editor James M. Berklan, Senior Editor Elizabeth Newman and Staff Writer Marty Stempniak.

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