Skilled Nursing Facility Assessment: Valuable & Not Complex

Last summer, CMS issued proposed changes to the Requirements of Participation for Nursing Homes (RofP). They requested comments on the proposed changes and the stakeholder community was neither quiet nor shy in expressing its opinions. Since that time, CMS has been mum on the issue and we can only assume they’re going through the comments and determining next steps. The best guess is that CMS intends to have the new rules issued in 2016 and that some of the provisions may be phased in over time.

In my last blog, I wrote about the proposed changes related to staff competency and skills. I provided an example of how to demonstrate that staff are competent to adequately carry out their duties. One of the components of my example was the need to conduct a facility assessment. You may wonder, what is a facility assessment? An assessment simply identifies the number and type of patients/residents under your care. Its purpose is to determine what resources are necessary to provide adequate care for patients and residents.

The proposed regulation requires the assessment to be done, “as necessary and at least annually.” How do you determine the correct frequency for your organization? Well, it depends upon the degree of change in your patient/resident population. If you have numerous admissions and discharges and a wide range of diagnoses and multiple comorbidities, then you will need to do your assessment more frequently than if you have a stable, long-term care population that undergoes little change over time.

Here are the steps to take for a skilled nursing facility assessment:

1) Identify the number of patients/residents under your care

Track your average daily census, as well as the average number of admissions and discharges you have during a specified time period. The census obviously helps you determine how many staff you need. The number of admissions and discharges provides insight into the type of care you provide; whether you have primarily a long-term care or short stay population. It can also help you determine your licensed nursing needs, as new admissions and discharges require specific types of care, e.g. assessments and discharge teaching, that only licensed nurses can provide.

2) Identify the acuity of your patients/residents

This step is a bit more complex and requires you to identify the type of care your patient/resident population requires including the range of diagnoses, the types of treatments, equipment, and medications. This information can be found in the history and physical, nursing assessment, MDS, care plan and MAR.

Regardless of whether CMS ultimately requires SNFs to conduct a facility assessment or not, it is a helpful tool that allows you to determine the number and types of staff you need to provide care in your organization. For example, if you have a large population of patient/residents who were recently discharged from the hospital you need to be sure you have adequate numbers of licensed nurses who can assess change in condition and collaborate with practitioners to implement treatments and avoid re-hospitalizations. Similarly, if you have a large population of individuals with behavioral issues related to dementia, you need to be sure that your staff is skilled at non-pharmacological interventions thus enabling you to avoid the inappropriate use of antipsychotic medication.

In summary, conducting a facility assessment will give you the information you need to make sure you have the right numbers of competent staff to care for your patients/residents. Implementation of a good facility assessment process will enable you to achieve both high quality care and regulatory compliance.