Deficiency-Free Complaint Surveys<p>State agencies survey skilled nursing centers to ensure they are meeting state and federal standards for quality and staffing set by the Centers for Medicare &amp; Medicaid Services (CMS). These survey agencies respond to all reported complaints by residents, families, and facilities (i.e., self-reported incidents) through complaint surveys. </p><p><a href="/Issues/2024/Documents/By%20The%20Numbers.pdf" data-feathr-click-track="true" data-feathr-link-aids="60b7cbf17788425491b2d083" target="_blank"><img class="ms-asset-icon ms-rtePosition-4" src="/_layouts/images/icpdf.png" alt="" />By The Numbers.pdf</a><br></p>2024-03-11T04:00:00Z<img alt="" src="/Issues/2024/Spring/PublishingImages/PrvSpr24_BTN.jpg" style="BORDER&#58;0px solid;" />Survey and CertificationA deficiency-free complaint survey means that a facility is being operated in absolute compliance with state and federal regulations.
Don’t Fear the Survey: 3 Tips for Using Survey Data to Your Advantage<p><img src="/Articles/PublishingImages/740%20x%20740/survey.jpg" class="ms-rtePosition-2" alt="" style="margin&#58;5px;width&#58;200px;height&#58;200px;" />​The state surveyors just exited your building, and you can hear the collective sigh of relief from your team. Post-survey can be a stressful time when your teams are prioritizing corrections and regaining compliance. Don't miss the opportunity to improve long term business performance and quality improvement with key insights from the data collected during the survey.</p><p>In today’s competitive and ever-increasingly data-driven marketplace, understanding how to use survey data to your advantage is key for successful outcomes. Beyond just creating and executing a plan of correction for survey deficiencies to get back in compliance, key insights can be gained from survey data on an ongoing basis for many different stakeholders to use in improving both quality of care and business performance.&#160;</p><p>The frequency of surveys and prevalence of deficiencies have increased since the COVID-19 pandemic in many states. The silver lining is that there is also an increase in data that your corporate leaders can use to identify operational issues and regulatory trends across your organization. By utilizing survey data effectively, operators can develop better audit tools and process improvements. However, accomplishing this is easier said than done.&#160; </p><h3>Using Data to Your Advantage</h3><p>Here are three ways in which you can use data to your advantage.<br><strong>1.&#160;&#160; &#160;Scale improvement efforts.</strong><br>If the data shows that there are repeat deficiencies in one region or across the organization, you have an opportunity to use the data to create systemic change. Quantifying repeat deficiencies at the regional or organizational level informs the improvement and modification of policies, procedures, onboarding, and training. You don’t know the greater problem exists without analyzing the data first. </p><p><strong>2.&#160;&#160; &#160;Incentivize leaders.</strong><br>Comparing survey performance against company and market peers can be used to incentivize leaders and drive competitive performance improvement. When hiring new executive directors and resident care directors, using a tool that aggregates national seniors housing survey outcomes, providers can vet and explore leaders’ prior survey outcomes at facilities based on dates of employment to drive interview questions and performance validation. For existing community leaders, operators can use survey data to help evaluate performance over time and identify opportunities for improvement.</p><p><strong>3.&#160;&#160; &#160;Mitigate risk exposure.</strong><br>Identification of adverse survey performance can drive special conditions on loans and develop key metrics for use in loan covenants. To mitigate risk exposure, financial stakeholders should be aware of historical and current survey activity including adverse outcomes, severe citations, high volume of citations, fines, ban on admissions, stacked surveys, open survey timelines, conditional licenses, and failed revisits. Continued adverse survey performance and a lack of ability to achieve and sustain substantial compliance can have a negative impact on financial performance, community reputation, census, and staff retention, and may ultimately warrant considering a change in operator.&#160;</p><p>Analysis of survey data along with other available data, such as staffing and quality measures, can be a valuable tool in underwriting general liability and professional liability insurance coverage. Reviewing these key areas during the underwriting process identifies if the facility has received citations that resulted in actual harm or immediate jeopardy to resident’s health or safety.&#160; Citations at these levels have a higher potential for leading to legal action against a facility, but when there is the ability to further assess staffing levels and quality outcomes it provides context as to the overall risk exposure and potential defensibility of a facility when setting premiums and policy limits.</p><h3>Technology Makes Data Analysis Easier</h3><p>The stakes are high for lenders, investors, and insurers to ensure protection of facility licenses from risk exposure related to adverse survey outcomes that can lead to enforcement actions. Finding the right tool to analyze survey data is important.&#160; Not all technology is the same. Here’s what to look for in your analysis tools.</p><p><strong>Does it analyze the entire portfolio?</strong> Tools that enable a complete assessment of survey performance across an entire portfolio are key. Look for tools that allow you to create groups to view data quickly and easily across your organization and conduct comparative reporting for a collection of facilities at both a high-level and detailed perspective.</p><p><strong>Does it allow for benchmarking?</strong> Tools that offer peer and market performance benchmark measures are important. Look for tools that benchmark historical survey, citation, and penalty details.&#160;</p><p>Does it allow you to slice and dice data? Data isn’t helpful if you can’t apply it to your specific needs. Make sure you can export data, use it in comparisons, and dynamically fold it in to other analysis tools.&#160;</p><p><strong>Does it allow for reporting?</strong> If the data is useful and helpful to your community, share it! Flexible technology allows you to report data to referral sources and prospective residents, strengthening those relationships with proof of your positive outcomes.</p><p><strong><img src="/Articles/PublishingImages/2023/MelissaFedun.jpg" class="ms-rtePosition-1" alt="" style="margin&#58;5px;width&#58;135px;" />Does it analyze state-level survey data?</strong> Tools that aggregate and analyze the state survey data of senior housing communities are critical to your success. This is especially important if you operate communities in multiple states because each state’s approach to the licensing and regulation of communities varies. Finding tools to make this data collection and analysis easier is imperative for directly comparing communities across state lines.</p><p>While most leaders and stakeholders are not thrilled when a survey team walks into their building to conduct routine or complaint inspections, top-performing operators are using the outcomes of survey activities to drive understanding and improve performance for their residents, staff, and business. Don’t let the data overwhelm you. Instead, find tools to make data analysis faster and easier to meet your regulatory and operational goals. <br><br><em><img src="/Articles/PublishingImages/2023/KyleGardener.jpg" class="ms-rtePosition-2" alt="" style="margin&#58;5px;width&#58;135px;height&#58;166px;" />Melissa Fedun, RN, BSN, is managing partner and co-owner of Formation Healthcare Group. She is a recognized industry expert providing clinical advisory services to identify risk exposure in investment management focused on seniors housing, post-acute, and healthcare real estate. </em><em><br></em></p><p><em>Kyle Gardner is the chief operating officer of NIC MAP Vision, a source for senior housing supply, demand, and operational data. </em><br></p>2023-10-17T04:00:00Z<img alt="" src="/Articles/PublishingImages/740%20x%20740/survey.jpg" style="BORDER&#58;0px solid;" />Survey and CertificationMelissa Fedun and Kyle GardnerDon't miss the opportunity to improve long term business performance and quality improvement with key insights from the data collected during the survey.
ACHCA Reboots Certification for Nursing Home and Assisted Living Administrators<p><img src="/Articles/PublishingImages/740%20x%20740/staff1.jpg" class="ms-rtePosition-1" alt="" style="margin&#58;5px;width&#58;200px;height&#58;200px;" />​Almost five years after the American College of Health Care Administrators (ACHCA) stopped offering its certifications for nursing home and assisted living administrators, the professional association for acute and aging services is bringing them out of retirement. <br></p><p>The ACHCA originally offered its certification program in 1981, sunsetting it in 2019 when the administration process became too cost prohibitive compared to the level of interest. “What we had found was that the exam had basically gone stale,” said Bob Lane, ACHCA president and CEO. “That was because the content hadn't continued to be updated.” <br></p><p>As the long term care industry underwent tectonic changes in recent years, ACHCA’s membership expressed increasing interest in the program’s renewal. Lane’s team knew, however, that they would have to make some changes.&#160;</p><p>“We used to have fairly prescriptive requirements, which we have now eliminated,” explained Dr. David Wolf, who chairs the ACHCA’s Certification Committee. The program no longer requires an active administrator’s license, broadening eligibility to academics, consultants, and others who wish to be certified non-practicing administrators. Nor does it require a set amount of experience in the industry or membership in ACHCA, though Wolf said he hopes administrators—practicing or non-practicing—recognize the value of membership. “Our goal is to help the administrator be the best they can be,” he said. “We offer lots of resources and support specifically for the administrator.”</p><h3>Proof of Mastery</h3><p>The rebooted certification program was developed by a certification committee, with extensive input from subject matter experts. The Nursing Home Administrator Certification (CHNA) exam is based on the four Domains of Practice established by the National Long-Term Care Administrator Boards (NAB)&#58; Care, Services, and Supports; Operations; Environment and Quality; and Leadership and Strategy. The Assisted Living Administrator Certification (CALA) exam, meanwhile, draws on NAB resources specifically tailored to assisted living. To receive certification, administrators must take a core exam with 100 questions, regardless of whether they’re pursuing CHNA or CALA certification. Then they must take a specific line-of-services exam for their desired certification, comprising 50 additional questions each.</p><p>Both Lane and Wolf stressed that the exam is far from easy. “We are looking for mastery, so the level of rigor of these questions is significantly more difficult than the licensure exam,” Lane explained. To that end, the ACHCA offers study materials, including both online and in-person boot camps. Wolf was careful to distinguish the program from the NAB’s Health Services Executive (HSE) qualification, which is an entry-to-practice exam rather than a demonstration of proficiency. <br></p><p>“We are offering a credential, which is a mastery of our profession, which is a higher level than the qualification that NAB offers through its HSE,” he said. “Once you become HSE-certified and you believe you fully understand our industry, you are welcome to take the certification examination.”</p><p>Applicants who take the exam immediately receive a pass/fail result, followed by a longer report from the ACHCA unpacking their performance in each domain. “I analogize it to lighting the runway. It helps light the path for that individual in terms of what their professional development needs are and where to focus,” Lane said. </p><h3>Paths to Recertification</h3><p>Whereas the original certification program required recertification every five years, the new one tightens that window to three, in keeping with the rapid pace of change in the industry. Recertification requires a total of 90 continuing education (CE) credits, with at least 18 in each of the NAB’s four domains of practice. That said, the ACHCA offers differing weights to various types of CE credits, creating several potential pathways to recertification.&#160;</p><p>For instance, the completion of a master’s or doctoral program in a relevant area generally constitutes an entire period’s CE requirements. Attendance at industry conferences like the LeadingAge Annual Meeting and Expo, the Argentum Senior Living Executive Conference, and the AHCA/NCAL Convention and Expo also constitute CE credits, provided the sessions are approved by the NAB or other relevant authorities. Service as a Bronze, Silver, or Gold Award Examiner with the AHCA/NCAL National Quality Award Program constitutes three CE credits, while presenters can earn six credits for the receipt of a Gold Award from the AHCA/NCAL’s National Quality Award Program. Other CE alternatives are explained on the ACHCA’s website.</p><h3>“It’s a Completely Different World”</h3><p>Matthew Lessard worked as a nursing home administrator in Maine before becoming Regional Director of Operations at National Health Care Associates. An ACHCA Fellow and recipient of its CHNA certification, he spoke highly of the certification program. “What becoming certified has meant for me is it is a testament to peers—others in the industry and even those outside of the industry—that the individual with certification has that level of mastery of the subject matter to be able to successfully operate a post-acute facility,” he said. “It’s a completely different world than it was 20 years ago when I started out as an administrator. Everything from reimbursement to the patients we take care of—they're the children of the patients we were taking care of 20 years ago.”</p><p><img src="/Articles/PublishingImages/2023/SethSimons.jpg" alt="Seth Simons" class="ms-rtePosition-1" style="margin&#58;5px;width&#58;170px;height&#58;170px;" />Asked what advice he’d offer to administrators early in their careers, he urged them to get involved in professional organizations. “You need to network, and you need to be connected to others, because—let's face it—the administrator of the facility doesn't have any peers within the facility,” he said. “Only another administrator is going to understand you, because no one else in any industry has the specific pressures that we have.”</p><p><em><span><em>Steve Manning is a journalist based in New York City.</em></span></em><br></p>2023-06-13T04:00:00Z<img alt="" src="/Articles/PublishingImages/740%20x%20740/staff1.jpg" style="BORDER&#58;0px solid;" />Survey and Certification;WorkforceSteve ManningAs the long term care industry underwent tectonic changes in recent years, ACHCA’s membership expressed increasing interest in the program’s renewal.
California Requires Medical Director Certification<p>On Oct. 6, 2021, Governor Gavin Newsom signed into law California’s Assembly Bill 749, which will require that all skilled nursing centers engage only medical directors who are certified by the American Board of Post-Acute and Long-Term Care Medicine (ABPLM, www.abplm.org) or will be so certified within five years.<br>This bill, which was sponsored by the <a href="http&#58;//www.caltcm.org/" target="_blank">California Association of Long Term Care Medicine</a> and supported by the <a href="http&#58;//www.cahf.org/" target="_blank">California Association of Health Facilities</a>, did not receive one single “Nay” vote in any of the committee votes or in the state’s Assembly and Senate and faced virtually no opposition from any stakeholder.</p><h2>Need is Established</h2><p>The COVID-19 pandemic has demonstrated unequivocally that engaged, knowledgeable medical directors can make a huge difference in the outcomes in skilled nursing centers, which helps explain the overwhelming popularity of this bill.<br></p><p>Many lawmakers and others were surprised to learn that in California, and in most states, the only requirement to be a nursing center’s medical director was an active medical license—allowing nursing centers to hire retired surgeons or pediatricians or engaging medical directors whose sole purpose appeared to be referring admissions without any discernible interest in ensuring competent geriatric medicine or adherence to the regulations was practiced in the building. <br></p><p>Still more shocking to some legislators and public health officials was the fact that unlike in hospitals, which have robust and rigorous credentialing and proctoring requirements for physicians to obtain admitting privileges, nursing centers are not required to do any more than the most rudimentary verification of a clinician’s licensure and, if they are wise, proof of liability insurance.<br></p><p>While some nursing centers and management organizations do have formal credentialing requirements, a great majority do not—so it falls to the medical director to perform quality assurance functions in ensuring that the other physicians and advanced practice practitioners are providing appropriate care and treatment within the standard of care. <br></p><p>Theoretically, the most incompetent physicians can practice in nursing centers, caring for medically complex, frail, vulnerable patients, with a similarly disengaged medical director not really monitoring the care that’s being provided. Not surprisingly, this was an alarming realization.</p><h2>Require Credentials</h2><p>The Certified Medical Director (CMD) certification from ABPLM involves physician candidates completing the Core Curriculum, which comprises 46 hours of content spanning 22 critical areas of long term care management. Each topic builds on information shared and interactive exercises of the topics that precede to create a comprehensive and cohesive picture of medical direction in long term care. <br></p><p>These include clinical topics that ensure basic knowledge of geriatric medicine and palliative care, leadership and bioethics content, and a detailed coverage of the federal regulations and requirements of participation for skilled nursing centers. The cost for the certification is about $3,000 in total.<br></p><p>There have been more than 4,000 physicians certified as CMDs since the inception of this program in 1991, and <a href="http&#58;//www.jamda.com/article/S1525-8610%2809%2900198-4/fulltext" target="_blank">a study by Frederick Rowland <em>et al.</em></a> published in the July 2009 issue of the<em> Journal of the American Medical Directors Association</em> found that quality metrics are better in facilities that have a CMD for their medical director.</p><h2>Personal History</h2><p>As a physician who was hired as a medical director back in the mid-1990s, I was admittedly clueless about many of the complex regulatory, clinical, and risk management issues associated with being a nursing center medical director. I looked for a professional medical society that could help educate me and quickly found AMDA (then called the American Medical Directors Association, but now called the Society for Post-Acute and Long-Term Care Medicine, <a href="http&#58;//www.paltc.org/" target="_blank">www.paltc.org</a>).<br></p><p>This organization, which is affiliated with the ABPLM, was a godsend to a young doctor just learning about nursing centers and how they operate. Though I may be biased, I strongly recommend that every nursing center exert any possible influence on its medical director to become a member of AMDA and its state or regional chapters, and to get CMD-certified. <br></p><p>Some physicians may balk at a request to take additional coursework or join a professional organization. It is clear that younger physicians are not “joiners” in the way that older doctors have traditionally been. So it may take a little persuasion, or even inserting language into medical director agreements that require a minimum number of CMD continuing education credits annually—or, better yet, an expectation that they become certified within a specified period of time.<br></p><p>It’s reasonable to consider time spent on obtaining a CMD, or attending courses that confer CMD credits, within the covered hours outlined in a medical director agreement or contract.</p><h2>What Residents Deserve</h2><p>Nursing centers today are like the hospitals, or at least the medical/surgical floors of hospitals, of a decade or two ago. Their residents deserve to have a competent, knowledgeable, and dedicated medical director as the medical leader and an integral part of the leadership and Quality Assurance and Performance Improvement team.<br></p><p>The CMD certificate through ABPLM is one way to guarantee at least a baseline level of knowledge that can move the needle on the quality of care provided.<br></p><p>It is likely that more states will follow California’s lead, and while a CMD requirement may pose a bit of a burden on the physicians serving in the medical director capacity, it may also help weed out those who really are not committed to the resident population—and is well worth it to give those residents and nursing centers the level of medical leadership they deserve. <br>&#160;<br><em>Karl Steinberg, MD, CMD, HMDC, is president of AMDA – The Society for Post-Acute and Long Term Care Medicine. He has been a nursing home and hospice medical director in the San Diego area since 1995 and is chief medical officer for Mariner Health Central and Beecan Health. ​</em></p>2021-12-01T05:00:00Z<img alt="" src="/Issues/Special-Features/PublishingImages/2021/1221/1221_MedDirect.jpg" style="BORDER&#58;0px solid;" />Survey and Certification Karl Steinberg, MD, CMDThe recent pandemic has demonstrated the need for geriatric- and long term care-qualified physician leaders in skilled nursing centers.