Comprehensive Care Plans are an OIG survey and enforcement focus area. The OIG published “OIG Executive Summary: Skilled Nursing Facilities Often Fail to Meet Care Planning and Discharge Planning Requirements (Feb 2013),” which states that 37% of SNFs surveyed did not meet Care Plan or service requirements. Based on its findings covering 2009 data, the OIG concluded that it paid $5.1 billion for stays in which SNFs did not meet care requirements, service requirements, or discharge planning requirements. According to the OIG, these deficiencies "raise concerns about what Medicare is paying for" and are evidence that, "CMS should do more to strengthen its oversight of SNFs to ensure that they perform appropriate care planning and discharge planning for [Medicare] beneficiaries."
OIG's specific recommendations to CMS include the following:
- Strengthening regulations related to care and discharge planning.
- Providing guidance to SNFs to improve care and discharge planning.
- Increasing surveyor efforts to identify SNFs that do not meet care and discharge planning requirements in order to hold SNFs accountable when they fall short.
- Linking payments to meeting quality-of-care requirements.
- Following up on the SNFs that failed to meet quality-of-care requirements to perform more comprehensive surveys.
Facility leaders need to ensure that their interdisciplinary team recognize and understand the importance of the RAI process and development of an effective Care Plan. Care Planning is the number one area directly correlating to outcomes. Care Plan goals and interventions directly relate to quality care, quality of life, survey outcomes, customer satisfaction and pay for performance.
We always recommend that facilities develop an initiative within their QAPI group to improve this process and provide their teams with the tools and education to improve outcomes.
What kind of initiatives have you implemented in your facility with regards to Care Planning goals?