As COVID-19 vaccinations accelerate and the country begins to reopen, long-term care facilities will soon have to face routine inspections and audits again.
Last March, both The Joint Commission (TJC) and the Centers for Medicare & Medicaid Services (CMS) pressed pause on audits, accreditation surveys, and health inspections due to COVID-19.
While CMS inspections and rating updates are now back in full swing as of January, TJC audits and surveys are proceeding more cautiously. According to a summer news release, TJC has resumed limited review activity with strict COVID-19 safety standards.
Passing audits and inspections are crucial to maintaining your nursing home’s accreditation and status as a Medicare-certified facility so you can stay in business. Here’s what your HR department should know about skilled nursing facility (SNF) audits and ratings, and how you can help prepare for them.
Skilled Nursing Facility Audits and Quality Rating System
Together, the CMS and TJC assess skilled nursing facilities’ patient care, quality of service, and provider qualifications.
The TJC survey and auditing process is designed to evaluate accredited nursing care centers once every 3 years through unannounced visits and documentation reviews that include:
- Assessments of patient safety
- Observations of services and provider or caregiver performance
- On-site or virtual staff interviews
- Physical survey of the facility
- Review of the facility’s ability to maintain updated practitioner documentation
The CMS tests nursing home quality levels using a five-star quality rating system, which is updated regularly on its facility comparison site, Nursing Home Compare. The site organizes nursing homes by rating and helps consumers and their families and caregivers choose the right facility. This rating system gives each nursing home a score of between 1 and 5 based on three major factors:
- Health inspections. This portion of the rating is a combination of the results from a facility’s three most recent health inspections and three most recent investigations due to complaints. Trained inspectors pay an on-site visit to test the nursing home’s ability to meet minimum quality requirements through a specific process.
- Staffing. This rating takes into account the average hours of RN care per resident day as well as total staffing hours (RN, LPN, and CNA) based on resident needs.
- Quality measures. This rating is based on 15 different physical and clinical measures to test how well nursing homes are meeting resident needs.
Tips for Audit and Inspection Preparation
Since audits and inspections are still not yet back in full force, this is an excellent time to review resources and optimize your facility’s approach.
As an employee-facing department focused on drawing in good talent, you want your facility to look good. By ensuring you have a strategy to stay on top of medical reviews and inspections, you can help your facility prepare for whatever comes their way and increase their rating at the same time.
Here are a few ways your team can improve compliance and maintain your SNF’s quality rating:
Educate staff about documentation
All nursing home facility staff should be on the same page when it comes to documenting and reporting care. Consider holding a staff meeting to go over the main points of documentation with your attending physician or RN in charge to emphasize the importance of including elements like:
- History of reticent care and behavior towards care
- The skilled services provided
- Need for services based on resident’s condition and situation
- Resident’s response to services
- Future care plan
All documentation should be legible and report care clearly and accurately. And make sure everyone knows to check state regulations for reporting and documenting COVID-19 procedures and care.
Improve employee satisfaction
Satisfied employees mean a better work environment and fewer complaints from residents, which can negatively impact your quality rating. Positive work cultures have been linked to better work attendance and performance, workforce retention, and mental health. It pays to ensure that your RNs, LPNs, CNAs, and other staff members are happy, healthy, and able to attend fully to their work.
Work with your staff to ensure that they’re getting what they need, whether that means flexible scheduling or healthy food on late-night shifts. Check in about their mental health and ask what resources you can provide to help them combat burnout.
Assess your technology
Both the CMS and TJC have had to adjust their on-site procedures during COVID-19. One of the major changes for both bodies has been the shift from in-person to virtual reviews, making it imperative for you to prepare for remote audits.
Do a quick assessment of the technology you have set up for videoconferencing, sharing electronic health records (EHRs), and accessing and sending staff documentation securely.
If you have conducted remote interviews recently, you may already have some of these tools in place. But do be sure that any solutions you use meet HIPAA and state data privacy and security regulations.
Emphasize time and attendance
In 2019, the CMS tightened their quality rating restrictions, reducing the number of days facilities could go without having an on-site nurse. This and other changes resulted in over one-third (37%) of Skilled Nursing Facilities losing one or more stars.
Your facility may not be able to recruit enough new nurses to fill your roster completely, which is why prioritizing timeliness is an important part of maintaining your rating. Make it a point to reward staff who clock in and out on time and stay on top of missed days and late arrivals. At the same time, keep in mind that pandemic fatigue can result in higher occurrences of sick days, so try to plan for some flexibility.
Keep HR documents up-to-date
Audits can happen at any time and you never know what additional records or information may be requested. This could include additional documentation on the patient, their condition, and the services provided, or verification of nursing staff’s state and federal licenses, certifications, and credentials.
TJC in particular will examine your nursing staff’s ability to provide patient care based on their qualifications and accreditation compliance standards. Review your employee screening and documentation monitoring processes from verification to renewal. And remember that primary source verification rests on you, so take care that your credentialing policy guidelines are clear and easy for every department and location to implement.
Digitizing HR Files for Easy Access
As you help prepare your facility for potential audits and inspections, it’s also a good idea to take a closer look at your system for storing and submitting documentation. Your personnel records may be up-to-date, but are they as accessible as they could be?
Many HR departments still handle paperwork manually, with paper folders and filing cabinets rather than a centralized system. And while this may still work for some, it can get tricky if you’re juggling multiple review requests or multiple facilities.
Digitizing files in a central location can help you avoid unnecessary compliance violations and simplify employee management. With access to all files at once, your facility can stay organized, prepare ahead of time, and have all the documentation you need at your fingertips, just in case.
Apploi brings healthcare HR process online, from recruitment to staff documentation management. Interested in learning more? Contact us today for a free demo of our end-to-end solution.
