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Category Archives: CMS Memo

ICD-10 Implementation Delayed

You may visit the CMS ICD-10 website for the latest news at www.cms.gov/Medicare/Coding/ICD10/index.html.

CMS Proposes Adoption of Updated Life Safety Code

To read the complete announcement, please visit CMS at www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2014-Fact-sheets-items/2014-04-14.html.

The Centers for Medicare & Medicaid Services (CMS) has announced a proposed rule on the adoption of updated life safety code (LSC) that CMS would use in its ongoing work to ensure the health and safety of all patients, family, and staff in every provider and supplier setting.  The updated code contains new provisions that are vital to the health and safety of all patients and staff.

A key priority of CMS is to ensure that patients and staff continue to experience the highest degree of safety possible, including fire safety.  CMS intends to adopt the National Fire Protection Association’s (NFPA) 2012 editions of the (LSC) and the Health Care Facilities Code (HCFC).  This would reduce burden on health care providers, as the 2012 edition of the LSC also is aligned with the international building codes and would make compliance across codes much simpler for Medicare and Medicaid-participating facilities.

PUBLIC INPUT INVITED:

The proposed rule is currently on display at http://ofr.gov/inspection.aspx and will be published in the April 16, 2014 Federal Register.  The deadline to submit comments is June 16, 2014.

To obtain this publication, you may also visit www.federalregister.gov/articles/2014/04/16/2014-08602/medicare-and-medicaid-programs-fire-safety-requirements-for-certain-health-care-facilities. The publication in .pdf format is available in the right-hand column or click here.

Antipsychotic Drug use in Nursing Homes: Trend Update

CMS is tracking the progress of the Partnership to Improve Dementia Care in Nursing Homes by reviewing publicly reported MDS quality measures. The official measure of the Partnership is the percentage of long-stay nursing home residents who are receiving an antipsychotic medication, excluding those residents diagnosed with schizophrenia, Huntington’s Disease or Tourette’s Syndrome.

Since the Partnership began in 2012, this data indicates Missouri’s percentage rates have dropped every quarter, with an overall decrease of 9.17 percent. This is encouraging and shows that Missouri is making improvements towards decreasing the use of antipsychotic medications for residents with dementia when their use is not indicated or appropriate. Please view the trend update here: CMS Trend Update – Antipsychotic Drug Use in Nursing Homes.

Cardiopulmonary Resuscitation (CPR) in Nursing Homes – Guidance Clarification Update

Guidance Clarification Update February 21, 2014

CMS Memo S&C: 14-01-NH

The Section for Long-Term Care Regulation (SLCR) wants to make certified providers aware that updated guidance from CMS (S&C: 14-01-NH) now requires “certification” of some nursing home staff as part of the nursing home’s compliance with regard to CPR.  Previously, if a question arose during a federal regulatory process regarding whether someone could perform CPR properly, a surveyor may have needed to ask for an explanation of appropriate technique from some available staff member to verify compliance with that requirement, but verifying the certification of a particular staff member typically was not necessary.

This most recent memo states that “certification” of some staff members is mandatory, but the memo does not clarify which certifying agencies are acceptable (i.e., American Heart Association).  SLCR and the Kansas City Regional CMS office requested a clarification of this point.

We have now received guidance indicating that the purpose of this memo was to, “…ensure that facilities do not implement facility-wide ‘no CPR’ policies and that facilities have CPR-certified staff available at all times,” but that CMS does not intend to review or approve all certification agencies.

A wide range of organizations offer CPR certification – some are based online and some are conducted in-person.  To this point, CMS has clarified that while S&C: 14-01-NH does not require the use of any specific certifying agency, there are two components that are required with regard to CPR certification:

  • The certification must be designed for healthcare providers (therefore, CPR courses for laypersons which teach chest compressions, but not mouth breathing, are not sufficient); and
  • Nursing home policies should address how staff members should maintain and document their CPR certification.

The American Heart Association certification is acceptable under this guidance, but it is not the only acceptable certification.  Many homes in Missouri are currently obtaining CPR certification through the American Safety & Health Institute (ASHI), which is also acceptable, as are others, as long as they are designed for professional healthcare providers.

You may view the memo here: CMS Memo S&C: 14-01-NH, or visit www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions.html.

Safety Reminders: Holiday Decorations

It is that time of year when people are decorating their homes and businesses with festive décor and anticipating upcoming holiday celebrations.  Residents and staff in your care home also look forward to festivities and enjoy holiday decorations.  It is important for residents, staff and visitors to carry on traditions and to feel a sense of joy and peace we all want this time of year.

The Section for Long-Term Care Regulation (SLCR) wants to help you and your residents have a safe holiday season by sending out the following safety tips, references and regulatory reminders.

Fires or other accidents are not something anyone wants! 

Safe decorations include:

  • Artificial Christmas trees, and decorations that are non-combustible or flame retardant.
  • UL approved decorative lighting (use in supervised areas and turn off when not in use).
  • UL approved outdoor lighting.
  • Holiday decorations, including evergreen wreaths, ornaments, photos, etc. can be used on resident’s doors, and in hallways, as long as they do not exceed 3 ½” in depth and they are not blocking the entrances or exits.*

*Any combustible decorations hung from doors or walls in corridors may be used with a waiver.  Non-rated combustible decorations cannot exceed 20% of the wall space in an exit egress corridor.

SLCR published an article regarding holiday decorating in the winter 2011 edition of the quarterly newsletter.  Please visit http://health.mo.gov/seniors/nursinghomes/providerinfo.php.

Although the 2000 Edition National Fire Protection Association (NFPA) 101® Life Safety Code (LSC) is the official reference, the 2012 Edition contains some less restrictive requirements.  Please refer to the CMS memo regarding waivers here: CMS Memo S&C 13-58-LSC 2000 Edition National Fire Protection Association (NFPA) 101® Life Safety Code (LSC) Waivers, or visit the CMS website at www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions.html.

Prohibited decorations include displays, hangings, and other decorations that block exits, visibility of exits, or fire protection appliances.  Never hang decorations from fire sprinkler heads or pipes.

NFPA 101, Section 19.7.5.4:  Combustible decorations shall be prohibited in any health care occupancy unless they are flame retardant.

NFPA 101, Section 7.1.10.1:  Means of egress shall be continuously maintained free of all obstructions or impediments to full instant use in the case of fire or other emergency.

NFPA 101, Section 7.1.10.2.1:  No furnishings, decorations, or other objects shall obstruct exits, access thereto, egress therefrom, or visibility thereof.

 

Please note, some county or city local ordinances may also require compliance with more restrictive standards, including the International Fire Code (IFC).

 

  • F323:  Electrical Safety – Any electrical device, whether or not it needs to be plugged into an electric outlet, can become hazardous to the residents through improper use or improper maintenance.  Electrical equipment such as electrical cords can become tripping hazards.  Halogen lamps or heat lamps can cause burns or fires if not properly installed away from combustibles in the resident environment.  The Life Safety Code prohibits the use of portable electrical space heaters in resident areas.

 

 

  • Can candles be used in nursing homes under supervision, in sprinklered facilities?

CMS Memo S&C-07-07:  Nursing Home Culture Change Regulatory Compliance Questions and Answers

Answer: Regarding the request to use candles in sprinklered facilities under staff supervision, National Fire Protection Association data shows candles to be the number one cause of fires in dwellings.  Candles cannot be used in resident rooms, but may be used in other locations where they are placed in a substantial candle holder and supervised at all times while they are lighted.  Lighted candles are not to be handled by residents due to the risk of fire and burns.

This holiday season, consider using battery-operated flameless candles.  They look and smell real!  Learn more about candle fire safety from the U.S. Fire Administration at www.usfa.fema.gov/citizens/home_fire_prev/holiday-seasonal/holiday.shtm.

If you have any questions regarding the Life Safety Code, please contact SLCR at 573-526-8524.  We wish you a wonderful and safe holiday season.

CMS Posts Errata Documents – MDS 3.0 RAI Manual

Please visit www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/MDS30RAIManual.html to view the November 5, 2013 update.

Nursing Home Quality Initiatives – Questions and Answers

The Centers for Medicare & Medicaid Services (CMS) and Advancing Excellence in America’s Nursing Homes national campaign coordination group developed a set of common questions and answers for nursing homes, in order to clarify how some of the many initiatives relate to and are aligned with each other.  The purpose is to help nursing homes better understand how to participate in and benefit from various initiatives.

  • Quality Assurance and Performance Improvement (QAPI)
  • National Nursing Home Quality Care Collaborative (NNHQCC)
  • National Partnership to Improve Dementia Care in Nursing Homes
  • Advancing Excellence in America’s Nursing Home’s Campaign
  • Alignment of Quality Initiatives

Questions include:

  • Must nursing homes use CMS QAPI tools and resources to be considered in compliance with the QAPI regulation?
  • What is the National Nursing Home Quality Care Collaborative (NNHQCC)?
  • What is a LAN?
  • How does the mission of the National Partnership to Improve Dementia Care in Nursing Homes align with non-pharmacological, person-centered care approaches?
  • What does a nursing home have to do to become part of Advancing Excellence?
  • How does QAPI overlap or align with topic specific initiatives such the NNHQCC, the National Partnership to Improve Dementia Care in Nursing Homes, and Advancing Excellence in America’s Nursing Homes?
  • If we participate in the NNHQCC or Advancing Excellence or the National Partnership to Improve Dementia Care in Nursing Homes, are we implementing QAPI?

Find the answers to these questions and more – click on the link below

CMSFAQsNHQualityInitiatives

This document is also available for download by visiting http://www.nhqualitycampaign.org/.

Cardiopulmonary Resuscitation (CPR) in Nursing Homes

CMS Memo S&C: 14-01-NH

The Section for Long-Term Care Regulation wants to make certified providers aware that this Memo requires “certification” of some nursing home staff as part of the nursing home’s compliance with regard to CPR.  CMS’ guidance had previously been that an on-duty staff member be able to perform CPR appropriately at all times.  If a question arose during a federal process regarding whether someone could perform CPR properly, a surveyor may have needed to ask for an explanation of appropriate technique from some available staff member to verify compliance with that requirement, but verifying the certification of a particular staff member typically wasn’t necessary.

One point that remains unaddressed in this new S&C Memo is that many different CPR training agencies offer “certification” of their own, and this Memo doesn’t specify which agency’s certifications are acceptable to CMS and which are not.  SLCR has requested a clarification of this point from the CMS Central Office, and so has the Kansas City Regional CMS office.  Neither of our offices have received a response.  When we receive further guidance, we will provide it to you via this Listserv.  Until then, we will not be altering our current survey practices, but we want to make providers aware that this new S&C Memo has been issued by CMS, and that depending on their answer to our questions, it’s likely that some of your staff may need to obtain CPR certification with very short notice.

Because this memo references the American Heart Association as a standard-setting organization with regard to CPR, it is our belief that provider certification through the AHA will almost certainly be deemed acceptable by CMS.  Whether other certifications will suffice is less clear at this time.  As soon as we have some clarification on this point, we will share it with you.  We apologize that we can’t offer more specific guidance at this time, and appreciate your patience.

View the CMS Memo S&C: 14-01-NH here:  Survey-and-Cert-Letter-14-01 or click here. 

UPDATED GUIDANCE HAS BEEN POSTED – PLEASE REFER TO:

http://health.mo.gov/blogs/ltcblog/2014/02/24/cardiopulmonary-resuscitation-cpr-in-nursing-homes-guidance-clarification-update/