Ask the payment expert ... about the observation stay loophole

What do new requirements mean about competency-based staffing? 

The Centers for Medicare & Medicaid Services’ final requirements of participation reflect the term “competency” quite a lot. This means that staff members need to have the knowledge and skills needed to care for residents as identified by the resident assessment and the individualized plan of care.

The requirements also identify specific training requirements for behaviors and dementia care. When you hire new staff, you need to make sure that they have the competency to care for your residents. That may require a competency-based skills checklist.

After employees are hired, you need to match staff competency with the acuity of residents. As you admit new residents, you need to ensure the staff members still have the competency to care for the resident. That might mean staff 1:1 training in any specific care that is outside the ordinary.

In addition, you need to base your staffing levels and assignments on your resident assessments. Temporary staff need to meet the same requirements, so you need to make sure the agencies you use provide you with staffing competency checklists and that you educate all staff in special requirements for your residents. 

A suggestion is that you hold skills fairs on an annual basis for licensed and unlicensed staff. This could include setting up stations for demonstration to validate their understanding of instruction. Records need to be maintained, including specific training, certifications and other records that verify competency. 

CMS also says that merely meeting minimum requirements such as certifications does not mean that the competency requirement is met. 

In a few years, competency requirements also will extend to dietary staff.