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Three questions to boost nursing home audit readiness

This column originally appeared in McKnights Long-Term Care News.

Nursing home and long-term care operators have already faced a number of key shifts since the beginning of 2023. Consider a recent example from the Centers for Medicare & Medicaid Services: an update on mental health conditions, specifically schizophrenia, could impact CMS star ratings.

As of late, there is increased scrutiny on the proper use of schizophrenia diagnoses, with investigations relying on proper documentation and background research of each patient. Most people support this. There’s certainly nothing wrong with wanting to prevent wrong diagnoses, and facilities shouldn’t have a problem producing internal documentation as well as supporting documents from referring clinicians.

However, it’s important to focus on all the details. Many long-term care leaders have concerns that their star ratings could plunge amidst the ever-evolving protocols. Consider all the implications that could create following an investigation. For example, it’s possible that at one point a diagnosis was defensible and accurate but perhaps was not renewed because a resident has been actively on antipsychotics for a long time.

These are the kinds of specific situations that can make audit preparation a challenge. Three questions can guide you, regardless of your circumstances.

Is the data working for you?
Audit readiness is an excellent reason to revisit your digital and recordkeeping systems. If you struggle to rapidly access the information that auditors ask for, that can be a red flag.

Determine things like how secure your data is, especially if it is stored in the cloud, and how easy it is to access any record you need. If you’ve outsourced certain responsibilities, like HR or payroll, gather some questions from your organization’s business partner and set up a conversation to review protocols and practices.

Do you have a thorough staffing plan in place?
It’s widely known that this is a tough labor market, but research proves a causal relationship between nursing home staffing levels and care quality and capabilities. Nonetheless, your workforce will need to be sufficiently up to par to the auditors’ satisfaction.

If you already know this area is problematic, make it a top priority to put a plan together that contains action items and next steps. A practical approach would be to offer regular compliance-based training and record attendance of when and how employees received vital information to successfully and safely do their jobs.

One often overlooked, but critical, element of recruitment and retention is culture. Like other performance indicators, employment culture can be quantified, measured, goal-oriented and improved. At least some of the reasons why long-term care struggles with recruiting is an often unfair reputation that these careers’ rewards are drowned out by negative job aspects. While nursing care is unquestionably a challenge, creating a strong culture and supportive working environment is possible, manageable and controllable.

What are your care team partners doing?
Returning to the above example of CMS’ renewed and changing focus on schizophrenia diagnoses, think about how many other parties and participants are subject to this process. It isn’t just the resident’s primary clinician or specialist, but pharmacists, pharmacy staff and the diagnostic and prescription guidelines being used.

You’re not assuming anyone is doing wrong by checking these details. The point instead is to be on the same page as everyone else concerning how residents should be diagnosed and treated. While this is important across the board, it’s especially essential that multi-state operators have robust systems in place to keep track of these relationships and any correlative information.

Nursing home and long-term care audits can and do change because regulatory and legislative standards shift. This isn’t news for tenured administrators and operators. However, it can easily become overwhelming to both stay informed of change and prepare your organization for minor pivots, rather than needing major overhauls – and this is especially true for multi-state operators.

Planning is critical for success, so take full advantage of resources that keep you informed of changes in real-time. Be proactive in making changes as necessary and give your organization and all impacted parties the opportunity to prepare.

Brian Evans is Adams Keegan‘s Vice President and Senior Care Practice Leader. He has served clients in senior care and home health for more than 20 years, providing guidance on how to leverage people, technologies, and processes to remove administrative burdens and maintain compliance.



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