CMS Updates Facility Assessment Requirements in State Operations Manual

On August 8, 2024, the Centers for Medicare & Medicaid Services (CMS) released a revised version of the State Operations Manual Appendix PP, with changes taking effect immediately. The primary updates are found under F838 §483.71, Facility Assessment.

The new regulations mandate that the facility assessment must now include a comprehensive evaluation of the resident population’s diseases, conditions, and physical or cognitive limitations. This includes assessing the acuity, which refers to the severity of residents’ illnesses and limitations, as well as any other pertinent information that may impact the services the facility must provide.

The assessment is crucial for guiding staffing decisions and determining the necessary skills and competencies staff must possess to deliver appropriate care. Additionally, it helps identify further needs for residents, such as physical space, equipment, assistive technology, individual communication devices, or other material resources required for their care.

In conducting the facility assessment, the facility must ensure active involvement from key individuals, such as the facility’s leadership, and direct care staff (e.g., nurses), and also solicit input from residents and families.

Also, under F540 §483.5 Definitions, the term “representative of direct care employees” has been added. This representative can be either an employee of the facility or a third party authorized by the direct care employees to provide expertise and input on their behalf for the purpose of informing a facility assessment.

Compliance Perspective

Issue

Facilities must conduct a comprehensive assessment to determine the resources necessary for competent care of residents during regular operations (including nights and weekends) and emergencies. This assessment must be documented and updated annually, or as needed, especially when planning for significant changes that would affect its components. Additionally, facilities must ensure adequate nursing staff with appropriate competencies and skills to deliver necessary services for resident safety and well-being, aligning with resident assessments, individual care plans, and the facility’s resident population characteristics per F838 requirements.

Discussion Points

    • Ensure your policies, procedures, and staffing guidelines are designed to provide quality care for all residents. Update them as necessary to align with the new CMS regulations. Review your facility assessment as required by F838 §483.71 to ensure it comprehensively addresses the needs of all residents, including their diseases, conditions, and physical or cognitive limitations. Update your facility assessment as needed.
    • Train staff responsible for hiring to develop innovative and effective strategies for recruiting and retaining staff. Ensure staff responsible for scheduling and distribution of available staff per unit are trained to meet the facility’s staffing levels, post this information as required by regulation, and secure staffing on all shifts. Train staff on their responsibility to provide safe, high-quality nursing care and support services that meet resident needs. Med-Net Academy Prime clients have access to clinical skill competency checklists adapted from Perry and Potter’s “Clinical Nursing Skills & Techniques 10th Edition.” For information on Prime, contact info@mednetconcepts.com.
    • Conduct periodic audits to ensure the number of staff needed to meet the acuity levels of all residents is being posted and that staffing requirements are met on all shifts daily. Also, audit to ensure staff are following policies for delivering safe, quality nursing care and support services. Ensure your facility assessment is current, thoroughly assesses the needs of all residents, and determines the resources required to provide high-quality resident care and services.

*This news alert has been prepared by Med-Net Concepts, LLC for informational purposes only and is not intended to provide legal advice.*

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