Using Quality in Focus as the foundation, Polaris Group highlights FTag 684 Quality of Care, the third most frequently cited FTag in FY 2023
CMS developed the Quality in Focus Program to help long-term care (LTC) facilities promote safe environments and educate the public about strict regulations in nursing facilities. Using this program, Polaris Group highlights FTag 684 Quality of Care, the third most frequently cited FTag in FY 2023.
Compliance with FTag 684 is crucial due to recent changes in the Nursing Home Enforcement Act, allowing CMS to impose more equitable civil monetary penalties (CMPs) for health and safety violations. These revisions aim to encourage facilities to correct and maintain compliance with CMS' requirements.
Starting in October, CMS will impose immediate CMPs for deficiencies in F684 Quality of Care, along with F550 Resident Rights and F675 Quality of Life. Penalties can now be applied both per day and per instance of non-compliance. This two-fold penalty aims to promote faster correction and sustained compliance.
FTag 684 covers all treatments and care provided to residents, addressing their physical, mental, and psychosocial needs. This includes standards of practice, staff competency, nutritional needs, pain management, and timely treatments like pressure ulcers.
Here are four recommendations to decrease potential or current FTag 684 issues and mitigate the risk of increased CMPs.
1. Identify your weaknesses.
Look at your last two state surveys. Review your complaint investigations. Are there duplications of areas cited for non-compliance? If so, start with repeat FTags and develop action plans on stated issues, listing new interventions, updating timelines and assigning accountability to specific team members or groups.
- Create ad hoc committees to focus on FTag duplicate areas. Any area cited more than once in the past 18 months, regardless of the type of survey, needs attention.
- If no Ftags are duplicates, identify and focus on high Scope and Severity tags, especially those at S/S levels of F or higher.
2. Involve your staff in creating action plans or Performance Improvement Plans (PIPs).
Communicate meeting agendas, meeting minutes and action deadlines to all employees throughout the facility.
- In staff-related areas only and using facility-owned property, post/print/email/text (work phones only) issues at hand, top priority areas and why they matter.
- Put the ugly on the table. People cannot be part of the solution if they are not aware of the problems. Show vulnerability, a sense of genuineness, and grace in all conversations.
3. Schedule a mock survey.
- Self-identification of ‘problem’ areas can be tricky. Sometimes it is hard to prevent turf wars. Let an ‘outside’ expert identify and educate.
- Consult professionally vetted organizations to support fact finding; to generate solution suggestions and help you gain traction.
4. Outsource clinical experts to ensure facility staff have the time, resources and support to initiate projects and monitor and manage timelines.
- Remote MDS programs allow full-time focus on reimbursement for facility MDS Coordinators/RN’s who are pulled to the floor to help cover a shift. Mandated staffing requirements are slowly but surely marching into our reality. You need to keep every RN you have.
- Remote record reviews specific to care plans and infection control audits are great avenues to address real-time omissions or inaccuracies. These can be tailored to fit your needs of monthly, quarterly, hybrid reviews on-site/remote, and/or specific training needs for DON’s.
Double G citations (citations that occur when a facility with a previous citation at a G level is cited again) at a G level are burgeoning. Statistics found on Long Term Care Community Coalition’s website indicate that in 2023, the average dollar amount per diem CMPs was $49,007, and the average total dollar amount per instance CMP’s was $13,246. Do your P&L reports reflect the availability of those kinds of surplus dollars?
Facilities with Double-G citations must face specific and automatic penalties, per CMS federal law. In 2023, 1176 facilities across the nation were issued 1526 Double G citations and paid $55,868.535.54 in per day CMP’s and $5, 722, 411.67 per instance CMP’s. Yes, those numbers are in the millions. . Repeat G-level deficiencies are outrageously expensive and negatively impact your 5-Star rating, your facility morale and your reputation in the community.
Focus on FTag 684 Quality of Care when considering where your vulnerabilities and risks might be, specific to regulatory compliance. CMPs related to F684 could result in financial ruin or fiscal productivity. $50,000 would go a long way towards recruitment and retention efforts, and a long way in improving resident services and overall facility spirit.
For further information on how the clinical experts with Polaris Group can assist you in achieving compliance with FTag 684 contact us today!
