Ensure you're providing culturally competent care in accordance with professional standards of practice
CMS policy §483.25(m) states that “The facility must ensure that residents who are trauma survivors receive culturally-competent, trauma-informed care in accordance with professional standards of practice and accounting for residents’ experiences and preferences in order to eliminate or mitigate triggers that may cause re-traumatization of the resident.”
How does your facility identify those residents who are trauma survivors? And then once identified, how does your facility staff practice to eliminate or mitigate re-traumatization?
Trauma and how to identify trauma survivors
According to CMS, 70% of adults in the United States have experienced some type of traumatic event, series of events, or set of circumstances which have caused physical and/or emotional harm. The exposure to trauma leaves a lasting impact on the person’s mental, physical, social, emotional, and/or spiritual well-being and function.
Examples of groups of people who have survived trauma include military veterans, abuse survivors, Holocaust survivors, people with a history of homelessness or incarceration, or people from marginalized groups who have experienced cumulative stress and/or racism throughout their lives.
Identifying trauma survivors requires more nuance and care than simply asking “have you experienced trauma?”. Obtaining a thorough social history, using a validated trauma and stressor exposure measure such as the Brief Trauma Questionnaire or the Trauma History Screen, and observing the resident for potential triggers are mechanisms to identify residents who may have a history of trauma.
Trauma-informed care is an approach to support trauma survivors
Trauma-informed care (TIC) is a method of care delivery that involves understanding, recognizing, and responding to the effects of trauma and acting to minimize triggers that may cause re-traumatization. While nursing home staff should absolutely employ TIC for residents who are trauma survivors, TIC is simply best-practice in providing person-centered care for all residents.
The four hallmarks of TIC that surveyors will be looking for (and will cite for FTag 699 insufficiency if not present) are:
1. Identifying cultural preferences of residents who are trauma survivors
Aspects of cultural preferences that nursing home staff need to consider and include in care plans include communication preferences, food preparation and dietary preferences, clothing preferences, cultural etiquette including voice volume and amount of eye contact, and physical contact and/or care provision by a person of the opposite sex. Surveyors will use the Facility Assessment to identify resident populations with unique cultural characteristics and will investigate how those preferences are supported in a particular facility.
2. Identify a resident’s past history of trauma
On admission, facilities need to identify a resident’s past history of trauma or a previous traumatic event through a thorough intake and screening process.
3. Identify triggers which cause re-traumatization
Examples of triggers which could potentially cause re-traumatization include physical touch, tone of voice, body odor, perfume, or objects that may have been used in traumatic events. Triggers are highly individualized and staff need to consider all the senses (sight, smell, sound, and touch) to ensure residents are not re-traumatized. These triggers need to be identified and documented in the care plan with plans to avoid triggers.
4. Approaches that are culturally competent and/or trauma-informed
FTag 656 ensures that every resident’s person-centered comprehensive care plan includes approaches that reflect the resident’s cultural preferences and documents how staff provide trauma-informed care. In a chart review, surveyors will look for descriptions of resident cultural preferences, values, and practices, approaches to meet resident preferences, and interventions to eliminate or mitigate triggers for those residents with a history of trauma.
Importantly, deficiencies in FTag 699 and 656 may trigger investigation and citation in other areas. For example, if surveyors note that staff are not providing culturally competent or trauma informed care, facilities may also be cited for FTag 726, Competent Nursing Staff.
Polaris Group consultants are knowledgeable and equipped to assist your team develop care plans that include interventions and approaches to identify and care for trauma. Polaris Group consultants can also provide cultural competence training to staff to ensure the requirements of this regulation are met.
