Harmony Healthcare Blog

Phase Two Requirements for Requirements of Participation (RoP): Top 13 Things You Need to Know

Posted by Kris Mastrangelo on Tue, Oct 24, 2017


Edited by Kris Mastrangelo

C.A.R.E.

Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency


1-Compliance.jpgPhase Two of the Requirements of Participation (RoP) is right around the corner.  I extracted the information from the regulation and “distilled and synthesized” for you to assimilate, share with staff and apply in a user-friendly fashion.  Remember: Breathe and Chunk.  (Meaning stay calm and learn this piece by piece).  Harmony Healthcare international (HHI) has your back and is working tirelessly to keep you abreast of the regulatory changes.

  1. Contact Information Availability

    Providing contact information for:
    • State and Local Advocacy Organizations
    • Medicare and Medicaid Eligibility Information
    • Aging and Disability Resources Center
    • Medicaid Fraud Control Unit

      Information and contact information for State and local advocacy organizations, including but not limited to the State Survey Agency, the State Long-Term Care Ombudsman program (established under section 712 of the Older Americans Act of 1965, as amended 2016 (42 U.S.C 3001 et seq.); and the protection and advocacy system (as designed by the state, and as established under the Developmental Disabilities Assistance and Bill of Rights Act of 2000).
    • Information regarding Medicare and Medicaid eligibility and coverage
    • Contact information for the Aging and Disability Resource Center or No Wrong Door Program
    • Contact information for the Medicaid Fraud Control Unit 
  1. Reporting Crimes

    The facility must develop and implement written policies and procedures that ensure reporting of crimes occurring in federal-funded long-term care facilities in accordance with section 1150B of the Act. The policies and procedures must include, but are not limited to, the following elements.
    • Annually notifying covered individuals, as defined at section 1150B(a)(3) of the Act, of that individual’s obligation to comply with the following reporting requirements.
    • Each covered individual shall report to the State Agency and one or more law enforcement entities for the political subdivision in which the facility is located any reasonable suspicion of a crime against any individual who is resident of, or is receiving care from, the facility.
    • Each covered individual shall report immediately, but not later than 2 hours after forming the suspicion, if the events that cause the suspicion result in serious bodily injury, or not later than 24 hours if the events that cause the suspicion do not result in serious bodily injury.
    • Posting a conspicuous notice of employee rights, as defined at section1150B(d)(3) of the Act.
    • Prohibiting and preventing retaliation, as defined at section 1150B(d)(1) and (2) of the Act. 
  1. Transfer and Discharge Documentation

    When the facility transfers or discharges a resident under any of the circumstances specified in paragraphs (c)(1)(i)(A) through (f) of this section, the facility must ensure that the transfer or discharge in the resident’s medical record and appropriate information is communicated to the receiving health care institution or provider. 

    Documentation in the resident’s medical record must include:
    • The basis for the transfer per paragraph (c)(1)(i) of this section.
    • In the case of paragraph(c)(1)(i)(A) of this section, the specific resident need(s) that cannot be met, facility attempts to meet the resident needs, and the services available at the receiving facility to meet the need(s).
    • The documentation required by paragraph (c)(2)(i) of this section must be made by:
      • The resident’s physician when a transfer or discharge is necessary under paragraph (c)(1)(A) or (B) of this section; and
      • A physician when transfer or discharge is necessary under paragraph (b)(1)(i)(C) or (D) of this section.
    • Information provided to the receiving provided must include a minimum of the following:
      • Contact information of the practitioner responsible for the care of the resident
      • Resident representative information including contact information.
      • Advance Directive
      • All Special Instructions or Precautions for the ongoing care, as appropriate.
      • Comprehensive Care Plan Goals.
      • All other necessary information, including a copy of the resident’s discharge summary, consistent with 483.21 (c)(2), as applicable, and any other documentation as applicable, to ensure a safe and effective transition of care. 
  1. Baseline Care Plan

    The facility must develop and implement a baseline care plan for each resident that included the instructions needed to provide effective and person-centered care of the resident that meet professional standards of quality care.  The Baseline Care Plan must:
    • Be developed within 48-Hours of resident’s admission.
    • Include the minimum healthcare information necessary to properly care for the resident including, but not limited to:
      • Initial Goals (Based on admission orders)
      • Physician Orders
      • Dietary Orders
      • Therapy Services
      • Social Services
      • PASARR recommendation, if applicable
    • The facility may develop a Comprehensive Care Plan in place of the baseline care plan if the comprehensive care plan:
      • Is developed within 48 hours of the resident’s admission.
      • Meets the requirements set forth in paragraph (b) of this section (excepting paragraph (b)(2)(i) of this section).
    • The facility must provide the resident and their representative with a summary of the baseline care plan that includes but is not limited to:
      • The initial goals of the resident.
      • A summary of the resident’s medications and dietary instructions.
      • Any services and treatments to be administered by the facility and personnel acting on behalf of the facility.
      • Any updated information based on the details of the comprehensive care plan, as necessary. 
  1. Staffing and Competencies

    Based on the Facility Assessment for the determination of sufficient number and competencies of staff.

    Nursing Services: The facility must have sufficient Nursing Staff with the appropriate competencies and skill sets to provide nursing and related services to assure resident safety and attain or maintain the highest practicable physical, mental, and psychosocial well-being of each resident, as determined by resident assessments and individual plans of care and considering the number, acuity and diagnoses of the facility’s resident population in accordance with the facility assessment required at § 483.70(e).

    The facility must ensure that licensed nurses have the specific competencies and skill sets necessary to care for resident’s needs, as identified through resident assessments and described in the plan of care.
  1. Behavioral Health Services
     
    • Each resident must receive and the facility must provide the necessary behavioral health care and services to attain or maintain the highest practicable physical, mental, and psychosocial well-being, in accordance with the comprehensive assessment and plan of care. Behavioral health encompasses a resident’s whole emotional and mental well-being, which includes but is not limited to, the prevention and treatment of mental and substance use disorders.
    • The facility must have a sufficient staff who provide direct services to residents with the appropriate competencies and skills sets to provide nursing and related services to assure resident safety and attain or maintain the highest practicable physical, mental and psychosocial well-being of each resident, as determined by resident assessments and individual plans of care and considering the number, acuity and diagnoses of the facility’s resident population in accordance with §483.70(e). These competencies and skills sets include, but are not limited to, knowledge of and appropriate training and supervision for:
      • Caring for residents with mental and psychosocial disorders, as well as residents with a history of trauma and/or post-traumatic stress disorder, that have been identified in the facility assessment conducted pursuant to §483.70(e), and NOTE: this requirement is implemented in Phase 3.Implementing non-pharmacological interventions.

        Based on the comprehensive assessment of a resident, the facility must ensure that:
        • A resident who displays or is diagnosed with a mental disorder or psychosocial adjustment difficulty, or who has a history of trauma and/or post-traumatic stress disorder, receives appropriate treatment and services to correct the assessed problem or to attain the highest practicable mental and psychosocial well-being;
        • A resident whose assessment did not reveal or who does not have a diagnosis of a mental or psychosocial adjustment difficulty or a documented history of trauma and/or post-traumatic stress disorder does not display a pattern of decreased social interactions and/or increased withdrawn, angry, or depressive behaviors, unless the resident’s clinical condition demonstrated that development of such a pattern was unavoidable; [Note: (b)(1) and (b)(2) were implemented in Phase 1] and
        • A resident who displays or is diagnosed with dementia, receives the appropriate treatment and services to attain or maintain his or her highest practicable physical, mental, and psychosocial well-being.

          If Rehabilitative Services, such as, but not limited to physical therapy, speech-language pathology, occupational therapy, and rehabilitative services for mental disorders and intellectual disability, are required in the resident’s comprehensive plan of care, the facility must:
        • Provide the required services, including specialized rehabilitation services as required in §483.65; or
        • Obtain the required services from an outside resource (in accordance with §483.70(g) of this part) from a Medicare and/or Medicaid provider of specialized rehabilitative services.

          The facility must provide medically-related Social Services to attain or maintain the highest practicable physical, mental, and psychosocial well-being of each resident. [Note: (d) was implemented in Phase 1]. 
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  1. Medical Chart Review and Psychotropic Drugs

    Pharmacy Services (Drug Regiment Review)
    • This review must include a review of the resident’s medical chart.
    • Psychotropic Drugs: Based on a comprehensive assessment of a resident, the facility must ensure that:
      • Residents who have not used psychotropic drugs are not given these drugs unless the medication is necessary to treat a specific condition and diagnosed and documented in the clinical record.
        • Residents who use psychotropic drugs receive gradual dose reductions, and behavioral interventions, unless clinically contraindicated, to discontinue these drugs.
        • Residents do not receive psychotropic drugs pursuant to a PRN order unless that medication is necessary to treat a diagnosed specific condition that is documented in the clinical record; and
        • PRN Orders for psychotropic drugs are limited to 14 days. Except as provided in §483.45(e)(5), if the attending physician or prescribing practitioner believe that it is appropriate to the PRN order to be extended beyond 14 days, he or she should document their rationale in the resident’s medical record and indicate the duration for the PRN order.
        • PRN Orders for anti-psychotic drugs are limited it 14 days and cannot be renewed unless the attending physician or prescribing practitioner evaluates the resident for the appropriateness of that medication.
  1. Dental Services
    Loss or damage of dentures and policy for referral; Referral for dental services regarding loss or damaged dentures §483.55.
    • Must have a policy identifying those circumstances when the loss or damage of dentures is the facility’s responsibility and may not charge a resident for the loss or damage of dentures determined in accordance with facility policy to be the facility’s responsibility.
    • Must promptly, within 3 days, refer residents with lost or damaged dentures for dental services. If a referral does not occur within 3 days, the facility must provide documentation of what they did to ensure the resident could still eat and drink adequately while awaiting dental services and the extenuating circumstances that led to the delay; 
  1. Food and Nutrition Services

    As linked to the Facility Assessment.

    Staffing: The facility must employ sufficient staff with the appropriate competencies and skill sets to carry out the functions of the food and nutrition service, taking into consideration resident assessments, individual plans of care and the number, acuity and diagnoses of the facility’s resident population in accordance with the facility assessment required at §483.70(e). 
  1. Facility Assessment

    The facility must conduct and document a facility wide assessment to determine what resources are necessary to care for its residents competently during both day-to-day operations and emergencies.  The facility must review and update that assessment, as necessary, and at least annually.  The facility must also review and update this assessment whenever there is, or the facility plans for, any change that would require substantial modification to any part of this assessment.  The facility assessment must address or include:

    The Facility’s resident population, including, but not limited to:
    • Both the number of residents and the facility’s resident capacity;
    • The care required by the resident population considering the types of diseases, conditions, physical and cognitive disabilities, overall acuity, and other pertinent facts that are present within that population;
    • The staff competencies that are necessary to provide the level and types of care needed for the resident population;
    • The physical environment, equipment, services, and other physical plan considerations that are necessary to care for this population; and
    • Any ethnic, cultural, or religious factors that may potentially affect the care provided by the facility, including, but not limited to, activities and food and nutrition services. 

The facility’s resources, including but not limited to: 

  • All buildings and/or other physical structures and vehicles; 
  • Equipment (medical and nonmedical); 
  • Services provided, such as physical therapy, pharmacy, and specific rehabilitation therapies; 
  • All personnel, including managers, staff (both employees and those who provide services under contract), and volunteers, as well as their education and/or training and any competencies relation to resident care; 
  • Contacts, memorandums of understanding, or other agreements with third parties to provide services or equipment to the facility during both normal operations and emergencies; and 
  • Health information technology resources, such as systems for electronically managing patient records and electronically sharing information with other organizations.

    A facility-based and community based risk assessment, utilizing an all hazards approach. 
  1. Quality Assurance and Performance Improvement (QAPI)

    • Initial QAPI Plan must be provided to State Agency Surveyor at Annual Survey §483.75
    • Each LTC facility, including a facility that is part of a multiunit chain, must develop, implement, and maintain an effective, comprehensive, data-driven QAPI Program that focuses on indicators of the outcomes of care and quality of life.
    • The facility must present its QAPI plan the State Survey Agency no later than 1 year after the promulgation of this regulation.
  2.  Infection Preventions and Control Program

    As linked to Facility Assessment at §483.70(e) and (a)(3) Antibiotic Stewardship §483.80

    The facility must establish an Infection Prevention and Control Program (IPCP) that must include, at a minimum, the following elements:
    • A system for preventing, identifying, reporting, investigating, and controlling infections and communicable diseases for all:
      • Residents
      • Staff
      • Volunteers
      • Visitors
      • Other individuals providing services under a contractual arrangement based upon the facility assessment conducted according to §483.70(e) and following accepted national standards.
    • An Antibiotic Stewardship Program that includes antibiotic use and protocols and a system to monitor antibiotic use. 
  1. Physical Environment: Smoking

    Establish policies in accordance with applicable Federal, State, and Local Laws and regulations, regarding smoking, smoking areas, and smoking safety that also consider non-smoking residents.
Harmony Healthcare International (HHI) is available to assist with any questions or concerns that you may have.  You can contact us by clicking here.  Looking to train your staff?  Join us in person at one of our our upcoming Competency/Certification Courses.  Click here to see the dates and locations. 

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