NFAC Meeting Held

VHCA (3/23/07)

The Nursing Facility Advisory Committee (NFAC) held their quarterly meeting on Wednesday, March 21st to discuss topics related to the long term care survey and issues impacting operations of nursing facilities.  Co-chaired this year by Judith Brown, Vice President of Patient Services at Lake Taylor Transitional Care Hospital and Chairman of VHCA’s Quality of Care Committee and Chris Durrer, Director of the Office of Licensure and Certification (OLC), the committee discussed a series of issues that had been identified by VHCA’s Regulatory and Quality of Care Committees at their March meeting.  Among the agenda items discussed were the rise in “G” level citations, the need for clarification regarding DDNR orders, agreements with the State Police regarding Criminal Record Checks, and the importance of Life Safety Code surveys.

A review of survey trends and top deficiencies focused on the increasing number of “G” deficiencies cited already in 2007.  Between January 1, 2007 and March 5, 2007, there have been 24 deficiencies cited at a G level for surveys completed and entered into the system.  There have been no Immediate Jeopardy citations.  During that same time frame in 2006, there were 14 G level deficiencies and two surveys with Immediate Jeopardy citations. 

G deficiencies cited this year to-date were cited at the following tags: F309, F314, F324, F315, F329, F157, and F281

Providers continue to seek clarification on varying interpretations regarding their responsibilities for DDNR orders and the use of the yellow DDNR forms by nursing facilities.  Much of the confusion stems from the Durable DNR Fact Sheet available on the Department of Health’s website which states that, “When responding to a call from a nursing home or hospice, the EMS provider only needs to be shown an original Do Not Resuscitate Order in a patient’s chart.  This written directive must be signed by the patient’s doctor and dated.  It can be as simple as the doctor writing it on his prescription pad.  The EMS provider will indicate on his Pre-Hospital Patient Call Report form that he was shown a DNR order or told by the patient’s doctor that the patient has one.  Approved Durable DNR bracelets or necklaces can be honored in place of the Virginia Durable DNR Order form by EMS providers.” 

In spite of the information contained in this fact sheet issued by the Office of Emergency Medical Services, a number of our members report that EMS providers continue to require the completed, signed yellow DDNR form.  The NFAC, with the assistance of Susan Ward at the Virginia Hospital and Healthcare Association, is seeking clarification from the Attorney General’s Office.

Additionally, the OLC is seeking guidance from the Attorney General’s Office on a requirement by the Department of State Police in their User Agreement that requires destruction “by shredding or pulping all requested records after they have served the purpose for which they were requested.”  It is recommended that until this requirement by the State Police is clarified, facilities maintain invoices for the electronic requests for criminal records as documentation.

VHCA was asked by OLC to remind facilities of the importance of the Life Safety Code (LSC) in order to retain certification for Medicare and Medicaid and that the administrator must sign the LSC Plan of Correction.  The OLC has also clarified that facilities are required to secure all medications in a locked storage area and to limit access to authorized personnel only.  Storage areas may include, but are not limited to, drawers, cabinets, medication rooms, refrigerators and vehicles.  Schedule II medications must be maintained in separately locked, permanently affixed compartments. 

Minutes from the January NFAC meeting are now available.