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

Can you tell me more about the Facility Assessment that will be implemented in Phase 2 of the Rules of Participation? 

Although there is a specific F-tag (F-838) for the facility assessment, the requirements are really interwoven into many areas of the new rule.

The facility assessment needs to be completed annually. The purpose is to determine the resources necessary to care for your residents competently during each day and during emergency situations. 

The first component is assessing your resident population. What is your capacity and census, and what services are needed to care for each individual resident’s needs? Consider the types of diseases, conditions, physical and cognitive disabilities, and acuity.

This means you need to know your residents, what kind of conditions you are caring for and that you have the resources available to provide good quality of care. It also includes having staff who are competent to care for all the residents. You need the environments and equipment necessary to care for all residents and the ability to meet ethnic, cultural and religious factors that may affect their care.

Available resources also are an important part of this assessment. These resources may include your facility building structure, vehicles, services you provide, personnel available to provide care and outside resources.

The Centers for Medicare & Medicaid Services’ intent for this regulation is to ensure the facility evaluates its resident population and to identify the resources needed for its residents. 

Two other major issues and part of the facility assessment is determining the competency of staff and acuity of your residents. You need to understand the acuity of residents and make sure staff is competent to care for them.