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Ask the payment expert
Ask the payment expert
I understand that many facilities are being cited during state surveys for not following standards of clinical practice. That citation is frequently cross-referenced to the assessment process. 
What can we do to meet this challenge?

You are correct that we are seeing more and more citations reflecting staff not following these standards. The reason these citations are being cross-referenced to the assessment process is the identification of the reason for a deficient practice.

For any clinical process, you need to follow the four steps of the care process: assessment, development of the plan of care, implementation of the plan of care, and review and revision of the plan of care. 

So when a clinical system fails in a facility, the surveyor is going to look back to the assessment process to ensure the issue was assessed properly; if a care plan was developed; if the care plan was implemented; and if the plan was revised as needed.  If any of these steps are not followed, the situation is determined to be avoidable and the facility is cited.

The Centers for Medicare & Medicaid Services has instructed surveyors to look at all potential deficiencies that are affected by a specific deficient practice. So if the problem was due to missing or ineffective assessment, the assessment tag 

(F-272) may be cited. If it is a result of the lack of care planning, then the care plan tag (F-279) may be applied.

Also, the new interpretive guidelines that have been produced by CMS talk about standards of clinical practice based on 

“evidence-based” practice.  Basically, that means you can't implement processes just because you think it is the right way or because you've always done it that way. In today's practice, everything we do clinically must be based on “evidence-based” standards of clinical practice. 

If you do otherwise, you also can be cited for a F-281 violation.  

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