Alabama Nursing Home Association Convention May 3, 2012 Mia Sadler, RN Division of Healthcare Facilities
Alabama Nursing Home
Association Convention
May 3, 2012
Mia Sadler, RN
Division of Healthcare Facilities
News and Announcements
• New surveyors
• Wykeshia Horne – recently appointed as
LTC supervisor in Jefferson County
• QA Director
News and Announcements
• Infection Control Updates in NH –
CMS Webinar May 18, 2011 12:00 to
1:00 pm
• ANHA Infection Control Seminar –• ANHA Infection Control Seminar –
June 19, 2012
MDS 3.0
• Changes to MDS 3.0 Form and
Manual
• Effective April 1, 2012
• www.cms.gov/Medicare/Quality-
Initiatives-Patient-Assessment-
Instruments/NursingHomeQualityInit
s/NHQIMDS30TrainingMaterials.html
MDS 3.0
• ADPH – Healthcare Facilities –
MDS page
–www.adph.org/HEALTHCARE
FACILITIES/Default.asp?id=55
05
DINING PRACTICE STANDARDS
Pioneer Network – Food and Dining
Clinical Standards Task Force -
August 2011August 2011
www.pioneernetwork.net/Data/Do
cuments/NewDiningPracticeStand
ardsfinal8-26-11.pdf
Link to Survey and Certification
Letters (S&C letters)
• http://www.cms.hhs.gov/Medicar
e/Provider-Enrollment-and-
Certification/SurveyCertificationGCertification/SurveyCertificationG
enInfo/Policy-and-Memos-to-
States-and-Regions.html
Independent Informal Dispute
Resolution (IIDR) Process
• Required by the Patient Protection Affordable
Care Act
• Interim advance guidance – S&C 12-08-NH
(superseded S&C 12-02)(superseded S&C 12-02)
• Applies only to surveys, begun after 01/01/12,
which results in deficiencies with a scope and
severity level of G or above for which CMS has
imposed a CMP and is subject to being placed
in escrow.
Independent Informal Dispute
Resolution Process
• Letter from Dr. Geary dated April 10, 2012
included in the weekly round up notifying all
nursing home administrators that the
Alabama Department of Public Health’s policy Alabama Department of Public Health’s policy
was posted on the ADPH website:
– http://www.adph.org/healthcarefacilities/Default.
asp?id=688
Independent Informal Dispute
Resolution Process
• The CMS RO will communicate the
offer of the IIDR to the facility.
• The facility must request an IIDR • The facility must request an IIDR
to the State Agency within 10
calendar days of receipt of the
offer.
Independent Informal Dispute
Resolution Process
Within two working days of receipt
of the request the State Agency
will send a letter to the state and will send a letter to the state and
local ombudsman inviting them to
review the 2567 and provide
written comments.
Independent Informal Dispute
Resolution Process
• If there is a “involved resident”
the State Agency will send a letter
to the resident or the “resident to the resident or the “resident
representative” describing the
noncompliance and providing
contact information for the state
survey.
Independent Informal Dispute
Resolution Process
• The IIDR panel will provide a
written record of their
decision as soon as possible decision as soon as possible
but no later than ten calendar
days after completing the
review.
Independent Informal Dispute
Resolution Process• Upon receipt of the IIDR’s
recommendations the SA will:
–If no changes are recommended –If no changes are recommended
and the SA agrees, the SA will
send the results to the facility
and the RO within 10 calendar
days.
Independent Informal Dispute
Resolution Process
• If the SA agrees with IIDR
recommendations or has received a
final decision from the CMS RO and
changes need to the made to 2567, changes need to the made to 2567,
the SA will notify the facility and CMS
RO within 10 calendar days of
receiving the written record from the
IIDR.
Independent Informal Dispute
Resolution Process
• If the SA disagrees with any of
the IIDR recommendations,
the complete written record the complete written record
will be sent to CMS for review
and final decision.
Independent Informal Dispute
Resolution Process–No later than 10 calendar days the
RO will provide written notification
to the SA of the final decision. The
SA will send the final decision to the SA will send the final decision to the
facility within 10 calendar days of
receiving the final notification from
the RO.
Independent Informal Dispute
Resolution Process
• IIDR must be completed within 60 days of
the a facility’s timely request.
CMS National Initiative to
Improve Behavioral Health and
Reduce the use of
Antipsychotics in Nursing Antipsychotics in Nursing
Home Residents with
Dementia
CMS Webcast March 29,2012
CMS Webcast March 29,2012
Improving Behavioral Health and Reducing
Use of Antipsychotic Medications
Source: MDS National Quality Indicator System
https://www.cms.gov/MDSPubQIandResRep/02_qmreport.asp?isSubmitted=qm3&group
=10&qtr=23
Improving Behavioral Health and Reducing
Use of Antipsychotic Medications
• High prevalence rates of antipsychotic drug use in
nursing home residents have been reported in
several studies. Much of the use is in residents with
a diagnosis of dementia .a diagnosis of dementia .
• According to CMS’s QM/QI report, between July and
September 2010, 39.4% of nursing home residents
nationwide who had cognitive impairment and
behavioral problems but no diagnosis of psychosis
or related conditions received antipsychotic drugs.
2005 FDA Black Box Warning
• In April 2005, the FDA issued a black box warning of
increased risk of death associated with use of
atypical (second-generation) antipsychotics in
elderly population with dementia.
• Of seventeen placebo controlled trials of olanzapine
(Zyprexa), aripiprazole (Abilify), risperidone (Zyprexa), aripiprazole (Abilify), risperidone
(Risperdal), or quetiapine (Seroquel) in elderly
demented patients with behavioral disorders,
fifteen showed increased risk of mortality in the
drug-treated group compared to the placebo-
treated patients.
2008 FDA Block Box Warning
• In 2008, FDA extended the black box warning to the
conventional (first-generation) antipsychotics.
– Elderly residents with dementia-related psychosis
treated with conventional or atypical
antipsychotic drugs are at increased risk of death.antipsychotic drugs are at increased risk of death.
– Antipsychotic drugs are not approved for the
treatment of dementia-related psychosis.
Healthcare professionals should consider other
management options.
2008 FDA Black Box Warning
• Physicians who prescribe antipsychotics to elderly
patients with dementia-related psychosis (“off-
label” use) should discuss this risk of increased
mortality with their patients, patient’s families, and
caregivers caregivers
Source: Information for Healthcare Professionals: Conventional
Antipsychotics FDA ALERT [6/16/2008]
http://www.fda.gov/drugs/drugsafety/postmarketdrugsafetyinformatio
nforpatientsandproviders/ucm124830.htm
National Initiative
• CMS is developing a national action plan to improve
dementia care and non-pharmacologic
interventions in nursing homes, hoping to reduce
unnecessary antipsychotic medication use in
nursing homes.nursing homes.
• Goal for the national initiative 15% reduction in the
prevalence rate by the end of CY2012 (from 20% to
17% or so)
How will the survey process support
this initiative? • Look to see that the facility is carrying out
certain processes (e.g., specific target
behaviors, goals of treatment, length of
anticipated time on the medication, how anticipated time on the medication, how
monitoring will be done)
How will the survey process support
this initiative?
• Require direct care staff and others to be
able to articulate, in surveyor interviews,
that person-centered care practices are
being usedbeing used
• Engage physicians, nurse practitioners
and other primary care providers, as well
as the medical director, in dialogue about
facility practices
How will the survey process support
this initiative?
Ensure that residents or families/legal
representatives have been engaged in the
decision-making process including being
informed about the risks and benefits of informed about the risks and benefits of
the medication, including the black box
warning, the rationale for use and target
behaviors .
THE MESSAGE
The message is NOT to take all residents with
dementia off antipsychotics.
The message is to do a better job of evaluating why
residents with dementia may be having the
behaviors and to try to improve the quality and the behaviors and to try to improve the quality and the
quantity of behavioral health interventions.
University of Iowa Website
www.healthcare.uiowa.edu/igec/IAADAPT
•University of Iowa College of Public Health worked
with the Iowa Health Care Association in developing
this website.
•Many resources on the website related to
antipsychotic drug resources
•Can request laminated copies of some of the
information
F329 Citations – FY2012
• National 6.0%
• Region 4.3%
• State 3.8%• State 3.8%
QAPI
• https://www.cms.gov/Medicare/Provider-
Enrollment-and-
Certification/SurveyCertificationGenInfo/QAPI.html