Hospitals and REITs must proactively communicate and perform their due diligence to manage risk and support partners and stakeholders.
Skilled Nursing facilities (SNFs) find themselves under the magnifying glass as the first cases of Coronavirus COVID-19 appeared within the walls of a Washington SNF. It’s not surprising as these facilities provide services to individuals most vulnerable to the virus, and if SNF patients are infected, the potential for increased rehospitalizations is high. The Centers for Medicare & Medicaid Services (CMS) released a memo last week revealing their priorities for nursing facility inspections effective immediately. The memo directed the states to suspend non-emergency inspections across the country, allowing inspectors to turn their attention to the most serious health and safety issues including infectious diseases and abuse.
Impact to SNF Survey Activity
For now, SNF survey activity is limited to the following (in Priority Order):
- All immediate jeopardy complaints (cases that represents a situation in which entity noncompliance has placed the health and safety of recipients in its care at risk for serious injury, serious harm, serious impairment or death or harm) and allegations of abuse and neglect;
- Complaints alleging infection control concerns, including facilities with potential COVID-19 or other respiratory illnesses;
- Statutorily required recertification surveys (Nursing Home, Home Health, Hospice, and ICF/IID facilities);
- Any re-visits necessary to resolve current enforcement actions;
- Initial certifications;
- Surveys of facilities/hospitals that have a history of infection control deficiencies at the immediate jeopardy level in the last three years;
- Surveys of facilities/hospitals/dialysis centers that have a history of infection control deficiencies at lower levels than immediate jeopardy.
How can you mitigate risks in your network of SNFs?
Two simple actions can go a long way in reducing your risk of increased rehospitalizations.
Proactively Communicate
Scheduling a proactive (possibly remote?) meeting with SNF leadership can go a long way in reducing the risk of exposing the residents to the virus as well as potentially avoiding additional inspection citations and public scrutiny. Is the facility following CDC recommendations? Are they staying abreast of conditions in their communities and ensuring staff vigilance and adherence to strict infection prevention practices? All facilities should have an Infection Preventionist on staff and lead the aggressive efforts to keep the virus out of the facility. Working with your partners to prevent the spread of the virus in the community can also improve communication and learning opportunities for all.
Do Your Homework
Take time to ask the SNFs about their survey history over the last 3 years. Do they fall into any of the priority categories for survey? F880 is the federal tag for Infection Prevention and Control and includes a very comprehensive list of requirements within the regulation. Has the facility been cited in the last 3 years for F880? What was the scope and severity of the citation – isolated, pattern or widespread? Is this a repeat deficiency from a prior year? Repeat deficiencies can certainly place a facility at higher risk to be monitored more closely.
Be Prepared
Given the serious threat to the health of nursing facility residents and the significant media attention surrounding the virus, you can be sure the states will approach their inspections of the prioritized groups with laser focus and intensity. CMS’ memo clearly indicated that these actions reiterate their commitment to taking critical steps to ensure America’s health care facilities are prepared to respond to the threat of the Coronavirus (COVID-19).
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