The Assisted Living Regulatory Process - Preparing for Successful Outcomes Presenters: Robert J. Lightfoot II, Esq. Michael S. Pochowski
ALFA Top 10 Deficiencies - 2012 • Information collected from state licensing agencies • Classification may differ for each state • Commonalities amongst the states
Common Deficiencies 1. Medication Administration 2. Resident Admission Requirements 3. Ongoing Resident Assessment 4. Maintenance and Building Code 5. Employee Training 6. Resident Care 7. Emergency Preparedness 8. Food Service 9. Employee Health 10. Administrative Record Keeping
Medication Administration • Pertains to administration and assistance with self-administration • Not following through on physician orders • Timely administration • Medication Administration Record documentation
Resident Admission Requirements • • • • •
Obtaining necessary move-in information TB tests Medical evaluations Residency Agreement Documentation
Ongoing Resident Assessment • • • • •
Change of Condition Annual/Bi-annual Care Plan Updates Re-evaluation Follow-up
Maintenance & Building Code • • • • • • •
Physical building requirements Construction Building layout Furniture Cleanliness Water Temperature Hazard Free
Employee Training • • • •
New hire orientation Ongoing training Re-training Documentation
Resident Care • • • • •
Very Broad – Anything Care Related Preventing communicable diseases Providing appropriate care Resident Rights Following appropriate policies & procedures
Emergency Preparedness • Fire Drills • Emergency phone numbers • Evacuations – Tornado, hurricane, floods, etc. • Disaster Plan
Food Service • • • • • • •
Food Storage Temperature Safe-Handling Dietary Needs Meals and Snacks Nutritional Standards Proper Sanitation
Employee Health • • • •
TB Testing Communicable Diseases Infection Control Policies Appropriate Record Keeping • Annual Influenza Immunization
Administrative Record Keeping • • • • •
Quality Assurance Reports Updated Resident Logs Policies and Procedures Disclosure Documents Surveys and Plans of Corrections • Resident Record • Personnel File
Regulatory Risk Assessment High Risk Areas
Lesser Risk Areas
- Medications - Resident Care & Services - Documentation - Training - Ongoing Assessment
- Admission Requirements - Physical Plant - Emergency Preparedness - Food Service - Employee Health
Medications
TRAINING
Adequate Ongoing
SUPERVISION
Clinical – Delegation? Non-clinical PRNs, Psychotropics
DOCUMENTATION
MARs, Audits
Resident Care & Services - The Service Plan - Know the Regulations - Ongoing Training - Continuing Education - Standards of Practice - Incidents - response & reporting - Resources
Documentation including Administrative Record Keeping Audits Service Plan Review Employee Records Medication Reviews Fire Safety Records Evacuation Drills Admission Documents Advanced Directives Financial Records Payor Source Documents Emergency Contact Info
Training Administrative Records Competency Delegation Continuing Education Incident Reporting Abuse Reporting Resident Rights Standard Precautions Fire Safety Client Group
Ongoing Assessment The Service Plan Change in Condition Key Areas: - Behaviors - Medications - Pain - Nutrition
Admission Requirements
- Comprehensive Assessment - Appropriate for the Community
Physical Plant
Scheduled Maintenance Hazards
Emergency Preparedness Building & Safety Committee Evacuation Assessments Drill Documentation Local Fire Authority
Food Service Sanitary Food Prep Resident Council Training Temps
Employee Health
Documentation Initial Screening
Documentation
Documentation
Documentation
During the Survey Notification Point Person Shadow Cooperate Fix Answer and Refer Additional Documents Investigate Exit meeting Attitudes
Post Survey Evaluate violations Appeal vs Take Your Lumps Compliance History Corrections
Bob & Mike say
"Thank You!"