§483.75(c) Program feedback, data systems and monitoring. A facility must establish and implement written policies and procedures for feedback, data collections systems, and monitoring, including adverse event monitoring. The policies and procedures must include, at a minimum, the following:
§483.75(c)(1) Facility maintenance of effective systems to obtain and use of feedback and input from direct care staff, other staff, residents, and resident representatives, including how such information will be used to identify problems that are high risk, high volume, or problem-prone, and opportunities for improvement.
§483.75(c)(2) Facility maintenance of effective systems to identify, collect, and use data and information from all departments, including but not limited to the facility assessment required at §483.70(e) and including how such information will be used to develop and monitor performance indicators.
§483.75(c)(3) Facility development, monitoring, and evaluation of performance indicators, including the methodology and frequency for such development, monitoring, and evaluation.
§483.75(c)(4) Facility adverse event monitoring, including the methods by which the facility will systematically identify, report, track, investigate, analyze and use data and information relating to adverse events in the facility, including how the facility will use the data to develop activities to prevent adverse events.
§483.75(d) Program systematic analysis and systemic action.
§483.75(d)(1) The facility must take actions aimed at performance improvement and, after implementing those actions, measure its success, and track performance to ensure that improvements are realized and sustained.
§483.75(d)(2) The facility will develop and implement policies addressing: (i) How they will use a systematic approach to determine underlying causes of problems impacting larger systems; (ii) How they will develop corrective actions that will be designed to effect change at the systems level to prevent quality of care, quality of life, or safety problems; and (iii) How the facility will monitor the effectiveness of its performance improvement activities to ensure that improvements are sustained.
§483.75(e) Program activities.
§483.75(e)(1) The facility must set priorities for its performance improvement activities that focus on high-risk, high-volume, or problem-prone areas; consider the incidence, prevalence, and severity of problems in those areas; and affect health outcomes, resident safety, resident autonomy, resident choice, and quality of care.
§483.75(e)(2) Performance improvement activities must track medical errors and adverse resident events, analyze their causes, and implement preventive actions and mechanisms that include feedback and learning throughout the facility.
§483.75(e)(3) As part of their performance improvement activities, the facility must conduct distinct performance improvement projects. The number and frequency of improvement projects conducted by the facility must reflect the scope and complexity of the facility's services and available resources, as reflected in the facility assessment required at §483.70(e). Improvement projects must include at least annually a project that focuses on high risk or problem-prone areas identified through the data collection and analysis described in paragraphs (c) and (d) of this section.
§483.75(g) Quality assessment and assurance.
§483.75(g)(2) The quality assessment and assurance committee reports to the facility's governing body, or designated person(s) functioning as a governing body regarding its activities, including implementation of the QAPI program required under paragraphs (a) through (e) of this section. The committee must:
(ii) Develop and implement appropriate plans of action to correct identified quality deficiencies; (iii) Regularly review and analyze data, including data collected under the QAPI program and data resulting from drug regimen reviews, and act on available data to make improvements.
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Observations:
Based on a review of the facility's plan of correction from the survey ending January 26, 2024, the outcome of the activities of the facility's quality assurance committee, current staffing of the facility's food and nutrition services department, menus and menu extensions, observations and interviews it was determined that the facility's procedures failed to effectively identify ongoing deficient practices related to the facility's food and nutrition services department, and its lack of effective oversight, and implement effective plans to correct and prevent further quality deficiencies related to menus, snacks and food service sanitation.
Findings included
During the survey ending January 26, 2024, deficient facility practice was cited for the facility's failure to assure qualified full time staff responsible for the oversight of the food and nutrition services department. In response to that deficiency the facility developed a plan of correction, that included a quality assurance monitoring program, indicated that the facility will take the following steps:
In coordination with Nutraco, our consultant dietary company, there is a Registered Dietician performing oversight of our dietary department on a fulltime basis primarily in facility, with remote work as needed. The RD will provide consultant services to the food service manager and assist with daily kitchen operations to ensure compliance. Education has been provided to dietary director and dietician on the necessary oversight functions for the dietary department. Administrator or designee will conduct weekly audits x 4 weeks then monthly x 4 months of consultant dietician timecards to ensure fulltime status as well as oversight and sign off of facility menus with results reported to QAPI as needed.
However, at the time of this current survey, ending April 24, 2024, quality deficiencies in dietary services, and the operations of the food and nutrition services department were identified as follows:
Based on observations, review of the facility's planned written menus and menu extensions, and staff interviews, it was determined that the facility failed to follow planned written menus and failed to ensure that the facility's dietitian periodically reviewed the "always available" menu for appropriateness of the corresponding menu extensions for residents prescribed a therapeutic diet, including Resident A1.
Based on observations, review of the facility's planned written menus and menu extensions, and staff interviews, it was determined that the facility failed to follow planned written menus and failed to ensure that the facility's dietitian periodically reviewed the "always available" menu for appropriateness of the corresponding menu extensions for residents prescribed a therapeutic diet, including Resident A1.
Based on observation and staff interview, it was determined that the facility failed to maintain acceptable practices for the storage and service of food to prevent the potential for contamination and microbial growth in food, which increased the risk of food-borne illness.
The above quality deficiencies identified a lack of oversight of the food and nutrition services department and that the facility's plan of correction for the deficiency cited during the survey of January 26, 2024, was ineffective in correcting and/or sustaining corrections related to operations and oversight of the food and nutrition services department.
At the time of the survey ending April 24, 2024, the facility employed two part time registered dietitians (RD)
During the week of April 8, 2024 through April 19, 2024, the RDs worked the following onsite hours in the facility according to interview with the NHA on April 24, 2024:
April 8, 2024, 8 hours April 10, 2024, 8 hours April 11, 2024, 3.75 hours April 12, 2-24, 8 hours April 15, 2024, 8 hours April 17, 2024, 8.75 hours April 18, 2024, 8.75 hours April 19, 2024, 8 hours April 19, 2024, 4.25 hours
During an interview on April 24, 2024, at 1 PM with facility's dietary manager, who was recently hired on March 4, 2024, the dietary manager stated that presently, she had not yet successfully completed the certification requirements and was not yet qualified for the dietary manager position. The dietary manager confirmed that the facility used the services of two part time registered dietitians that performed primarily clinical nutrition duties. She stated that they were available to her for consultation "if she needed anything regarding running the kitchen." The dietary manager stated that she was responsible for the oversight of the kitchen.
Based on the outcome of the survey ending April 24, 2024, the facility failed to demonstrate that the Registered Dietitians provided sufficient oversight of the operations of the facility's dietary department, dietary staff and food service management.
Refer F803, F809 and F812
28 Pa. Code 201.18 (e)(2)(3)(4)(6) Management
| | Plan of Correction - To be completed: 05/28/2024
1. The facility cannot correct the cited deficiency as it occurred in the past. 2. The facility has created a dietary QAPI subcommittee consisting of administrator, don, registered dietician, dietary manager, and available dietary staff to better monitor dietary issues and quickly implement fixes. 3. All staff have been educated on the QAPI process. 4. Administrator or designee will conduct QAPI audits weekly x 4 and monthly x2 to ensure that all noted QAPI processes are being followed and implemented as recommended by the committee.
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