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

With the new survey process, does that mean other survey types have gone away?

With the recent emphasis on the new Requirements of Participation (RoP) and the new survey process, many have forgotten that Centers for Medi- care & Medicaid Services still has many initiatives in place.

One is the Dementia survey, which was expanded nationwide in 2015. Dementia focus surveys are still occur- ring. At least one recently took place by federal surveyors after the implementation of the new survey process Nov.28, 2017. Both the issues being identified in the dementia survey pro- cess and the MDS-focused survey are now also integrated into the new survey process.

If you review the new F-Tags for Resident Assessment (F635 – F646), you will see that all aspects of the Resident Assessment process are reflected including accuracy of assessments, coordination/certification of assessments and encoding/transmission of MDSs. All of these areas will be focus- ing on your overall MDS process.

Dementia also is an added part of the Behavioral Health (F740 – F745) tags. Under this category you will find F744 – Treatment/Service for dementia. This includes areas such as sufficient, competent staff, systematic care, managing challenging behaviors and person centered individualized care plans.

Although all are important, staff training in dementia care is essential to having a great dementia program.
If you have a secured unit, make sure you review the activity programming to accommodate the different levels of dementia.

Both the MDS and the Dementia care areas have Critical Element Pathways that you can use to evaluate yourself to see if you are in compliance.

Please send your payment-related questions to Patricia Boyer at [email protected].