Nursing home operators should be on high alert about the questions surveyors will ask employees about sufficient staffing after heavy emphasis was placed on the matter in updated guidance released this week by the Centers for Medicare & Medicaid Services.
CMS now plans to incorporate Payroll Based Journal staffing figures into investigations about potential noncompliance with nurse staffing requirements. Surveyors will be looking for problems such as insufficient staffing, lack of a registered nurse for eight hours each day, and a lack of licensed nursing for 24 hours a day.
If surveyors develop concerns after research and staff interviews, they will be directed to dig deeper to determine the severity of noncompliance.
“While administration may feel the facility is adequately staffed, direct care staff may not agree,” noted Amy Stewart, vice president of education and certification strategy for the American Association of Post-Acute Care Nursing.
AAPACN suggests that facility leaders in response should review F725 (sufficient nursing staff) and F727 (registered nurse coverage) tags and “pay particular attention to the interview questions that surveyors will ask staff about sufficient staff,” Stewart told McKnight’s Long-Term Care News on Thursday.
She also stressed the importance of providers submitting their PBJ data on time. She added that updates to Appendix PP instruct surveyors to cite if PBJ data is missing from CASPER reports.
“Providers should also know that although the PBJ staffing data report uses four or more days without an RN coverage, surveyors are instructed to consider a citation when there is one day without coverage,” Stewart warned. “The same holds true for if the facility has days without any licensed nurse.”
Overall, there are 98 additional pages added to Appendix PP in the updated guidance.
“Facility leaders need to review these regulatory changes in depth because they are significant,” Stewart said. “Once they have a better understanding of the changes, they can begin to map out next steps.”
She said providers should start by examining processes and policies related to the changes; note the policies that need updating; and then plan and staff education related to the necessary changes.
“In addition, be on the lookout for the updated Critical Element Pathways and use them to review the effectiveness of facility processes,” she counseled.
The updated guidance will go into effect on Oct. 24, 2022, giving “ample time for surveyors and facilities to be trained on this new information,” CMS said.
The new federal guidelines came just a day after Evan Shulman, director of CMS’ nursing home division, told attendees at the 35th national NADONA conference that updates were imminent.
“Leveraging PBJ data more thoroughly” is the goal, he said. “It is the most robust staffing data of nursing homes that exists. But for the most part, it exists in its own silo.”
“Something we’ll be looking at is how we can use this robust data and how we can use it to inform surveyors on standard surveys so they can be more in the know of what type of staffing this facility typically provides,” he added.