§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 review of the facility's plans of correction for previous surveys, and the results of the current survey, it was determined that the facility's Quality Assurance Performance Improvement (QAPI) committee failed to maintain compliance with nursing home regulations and ensure that plans to improve the delivery of care and services effectively addressed recurring deficiencies.
Findings include:
The facility's deficiencies and plans of correction for State Survey and Certification (Department of Health) survey ending June 22, 2024, revealed that the facility developed plans of correction that included quality assurance systems with audits to ensure that the facility maintained compliance with cited nursing home regulations. The results of the audits were to be reported to the QAPI committee for review. The results of the current survey, ending May 30, 2024, identified repeated deficiencies regarding ensuring that the resident's environment was free of accident hazards, preventing issues with the accountability of controlled medications (drugs with the potential to be abused), and ensuring that clinical records were complete and accurately documented.
The facility's plans of correction for deficiencies regarding ensuring that the resident environment was free of accident hazards, cited during the survey ending on June 22, 2023, revealed that audits would be conducted and the results of the audits would be brought before the QAPI committee for further monitoring. The results of the current survey, cited under F689, revealed that the QAPI committee was ineffective in maintaining compliance with the regulation regarding ensuring that the environment was free of accident hazards.
The facility's plan of correction for a deficiency regarding the failure to account for controlled medications, cited during the survey ending June 22, 2023, revealed that the facility would complete audits and the results would be reviewed as part of quality assurance. The results of the current survey, cited under F755, revealed that the facility's QAPI committee was ineffective in correcting deficient practices related to the accountability of controlled medications.
The facility's plans of correction for deficiencies regarding complete medical record documentation, cited during the surveys ending on June 22, 2023, revealed that audits would be conducted and the results of the audits would be brought before the QAPI committee for further monitoring. The results of the current survey, cited under F842, revealed that the QAPI committee was ineffective in maintaining compliance with the regulation regarding complete medical records.
Refer to F689, F755, F842.
28 Pa. Code 201.14(a) Responsibility of Licensee.
28 Pa. Code 201.18(e)(1) Management.
| | Plan of Correction - To be completed: 07/09/2024
1.) The facility cannot retroactively correct. The Governing Body reviewed and revised its written policies and procedures for their QAPI plan and program. QAPI program will include an assessment of how feedback, data, and information are obtained, collected, and used to identify problems, opportunities for improvement, and to develop and monitor performance indicators. The governing Body implemented a new QAPI template tool that allows QAPI members to insert and track their data and information.
2.) The Governing Body reviewed and revised its written policies and procedures for their QAPI plan and program. QAPI program will include an assessment of how feedback, data, and information are obtained, collected, and used to identify problems, opportunities for improvement, and to develop and monitor performance indicators. The governing Body implemented a new QAPI template tool that allows QAPI members to insert and track their data and information.
3.) The governing Body/designee will train the NHA who will then train the QAPI committee members on the reviewed and revised policies and procedures for their QAPI plan and program. Training will also cover the new QAPI template to be implemented where QAPI members can insert and track their data and information. Training will include how information is obtained, collected, and used to identify problems, reporting, tracking, investigating, analyzing, opportunities for improvement, and to develop and monitor performance indicators.
4.) The NHA will audit the minutes of the special QAPI meeting addressing the plan of correction on the statement of deficiencies from both this and last year's annual surveys. This audit will include a review of the committee's identification of the root cause analysis using the iterative interrogative technique; "The 5 Why's". The results of these audits will be discussed with the governing body for accuracy and applicability. The governing body review will occur with the QAPI committee.
5.) The date of compliance is July 9, 2024. This plan of correction was developed in conjunction with the governing body.
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