CMS is undertaking a bold initiative to broaden quality assurance and performance improvement activities (QAPI) in nursing homes. In March 2010, Congress passed the Affordable Care Act. The Provisions set forth significantly expand the level and scope of required QAPI activities to ensure that facilities continuously identify and correct quality deficiencies as well as sustain performance improvement. The new QAPI regulations will include the requirement that all homes must submit to the Secretary a plan for the facility to meet QAPI standards and implement QAPI best practices, including how to coordinate the implementation of a QAPI plan with QAA activities conducted under existing regulations.
QAPI is not new to healthcare. Hospitals have been required to “take a proactive approach to improve their performance and focus on improved patient care and patient safety” through a QAPI program since 2003. Hospices have been required to have a QAPI program since 2008. So why not Long Term Care facilities? CMS seeks to change that.
An effective QAPI program is focused on creating effective systems to strategically manage all aspects of health care quality. Shunning the mere alleviation of a symptom, QAPI strives to dig deep into the root cause of an issue and seek a path for improvement for both internal and external customers.
The QAPI program is not just designed to address current problems in the facility. Rather, it is geared toward a proactive management of quality care. QAPI challenges facilities to consider areas where they are doing well and to strive for excellence.
For over 20 years, the existing QAA regulation for Long Term Care facilities has specified very minimal requirements. The requirement stated that each nursing home will have a QAA committee with certain members, and at least three other members of the facility’s staff that meet at least quarterly. This team is charged with the task of “developing and implementing appropriate plans of action to correct identified quality deficiencies”. This regulatory provision contains no specifications as to the means and methods taken or the action plans developed to implement the QAA regulations.
QAPI changes all that. For nursing homes, the new regulation will go far beyond this relatively ambiguous existing QAA requirement and require facility staff to continuously work to identify and correct quality concerns, as well as sustain performance improvement activities. Staff will be encouraged to identify areas where quality improvement is needed, participate in Root Cause Analysis to determine why quality improvement is needed, and identify Performance Improvement Projects (PIPs) that will lead to improved quality and customer satisfaction. All levels of staff are to participate, from board members to nursing assistants. It is truly a team approach to quality improvement.
Harmony (HHI) recommends facilities investigate the current strength of the QAA committee to determine how well the team is poised for the transition to QAPI. If the team is meeting only the minimum federal requirements, the facility will have a more difficult transition and will want to ensure plenty of time is allotted.
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