While the new regulations on Quality Assurance and Performance Improvement (QAPI) involve processes that go beyond the QIS methods, use of the QIS process addresses many aspects of such a program.

The next five columns will address how the QIS methods can be used in a QAPI system by showing the parallels between the five elements of QAPI included in the regulation and QIS methods.

To better understand the QAPI regulation that will be enacted in this year, go to www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-13-05.pdf.

Each column in this series will relate to one of the five QAPI elements, beginning with Element 1, the Design and Scope of a QAPI program:

“A QAPI program must be ongoing and comprehensive, dealing with the full range of services offered by the facility, including the full range of departments.

“When fully implemented, the program should address all systems of care and management practices and should always include clinical care, quality of life, and resident choice. It aims for safety and high quality with all clinical interventions while emphasizing autonomy and choice in daily life for residents (or residents’ agents).

“It utilizes the best available evidence to define and measure goals. Nursing homes will have in place a written QAPI plan adhering to these principles.”

If this description of the Design and Scope sounds overwhelming, it is! Breaking it down a bit, the first concept is that the QAPI program be “ongoing.” This column has previously described how the QIS process can be used continuously to assess quality in Stage 1 and improve performance in Stage 2.

The second concept is that a QAPI program must be “comprehensive.” While QIS does not address every single aspect of nursing home care, it does cover the full range of regulations, and through the various assessments and facility tasks it addresses the major “services offered” and “departments.”

The QAPI requirement to include “clinical care, quality of life, and resident choice” is certainly paramount in the QIS process with the range of assessments in Stage 1, including an emphasis on quality of life and choice. “Systems of care and management practices” are addressed in Stage 2 of QIS when one investigates what underlies problems identified in Stage 1.

“Aiming for safety” certainly underlies the regulatory aspects of QIS. Aiming for “high quality” requires the use of QIS methods not just to meet the minimum requirements set by Centers for Medicare & Medicaid Services thresholds for the survey process, rather to meet the highest possible quality goals using the same methods. And the QIS offers a unique set of evidence-based measures to “define and measure quality goals.”

Thus, while not providing a written QAPI plan, the QIS methods capture the spirit of this element of a QAPI
program and many of the tools that are needed to meet the intent of the regulation.