DQA Quarterly
Information Update
April 2012
PDF Version of this month's Quarterly Update (PDF,
132 KB)
NEW THIS ISSUE
UPCOMING EVENTS
REGULAR FEATURES
NEW THIS ISSUE
Hospice: Scope and Frequency of Services
Bureau of Technology, Licensing and Education
"Is a signed physician order needed?"
The question of whether or not a signed physician order is required
when there is a change in visit frequency has been asked a few times
recently. Neither the State nor Federal regulations for Hospice services
specifically identify that a signed physician order is needed.
Wisconsin Administrative Code DHS 131.21(3)(b) 2 states that the plan
of care shall include "a detailed statement of the scope and
frequency necessary to meet the specific patient and family needs."
The Federal Regulation that addresses this can be found in the State
Operations Manual at §418.56(c)(2): A detailed statement of the scope and
frequency of services necessary to meet the specific patient and family
needs.
The Interpretive Guidelines for §418.56(c)(2) state that the use of
visit ranges in the patient plan of care should follow these parameters:
- The plan of care (POC) may include a range of visits and PRN orders
for visit frequencies to ensure the most appropriate level of service
is provided to the patient.
- A range of visits is acceptable as long as it continues to meet the
identified needs of the patient/family.
- Visit ranges with small intervals are acceptable (i.e., 1-3
visits/week; 2-4 visits/week) but ranges that include "0" as
a frequency are not allowed.
- The Interdisciplinary Group (IDG) may exceed the number of visits in
the range to address patient/family's needs. There should be
documentation in the record to support the need for the extra visit(s).
- If the patient requires frequent use of PRN visits, the plan of care
should be updated to include the need for additional visits.
- Standing orders or routine orders must be individualized to address
the specific patient's needs and signed by the patient's physician.
- The IDG should be proactive in developing each patient's plan of
care by planning ahead for anticipated patient changes and needs.
Decisions should reflect the patient/family preferences rather than be
solely a response to a crisis.
CMS has provided the following clarification on this issue:
All hospice care and services furnished to patients and their
families must follow an individualized written plan of care established
by the hospice IDG in collaboration with the attending physician (if
any), the patient or representative, and the primary caregiver in
accordance with the patient's needs if any of them so desire. This plan
of care must also include a detailed statement of the scope and
frequency of services needed to meet the specific patient and family
needs.
CMS recognizes the importance of the IDG's assessment of an
individual patient, and requires hospices to update the comprehensive
assessment as frequently as the condition of the patient requires. The
hospice IDG should then identify when a change is needed to the plan of
care in order to meet the patient's identified needs.
CMS recognizes that the need for additional visits may occur with a
hospice patient and the interpretive guidelines allow for the use of PRN
orders for visit frequencies to ensure that the most appropriate level
of service is provided to address the patient/family's needs. CMS does
not regulate how PRN orders for visit frequency should be written.
Reasons for PRN visits could vary considerably and it would be difficult
to state the reason for every PRN visit before it occurs. Reasons for
the PRN visits, when they occur, should be documented in the clinical
note for that visit and must be conducted in accordance with accepted
professional standards of practice, and in compliance with the hospice
conditions of participation and any other Federal, State or local law.
The synergy of assessments, IDG approach and plans of care should
reflect the needs of the patient and how those needs are being
addressed.
It is important to stress that this response only applies to the
question of visit frequency. Signed physician orders are required under
any other circumstance as dictated by Standards of Practice, State or
Federal regulations, e.g., medication orders. Some other payer sources,
e.g., private health care insurance with a hospice benefit, may require
physician signed orders for visit frequency.
It is also critical that documentation clearly reflect the change in
the POC based on the IDG assessment of need and collaboration with
attending physician.
If you have any questions or need further clarification contact:
Trudy Ciszek, RN
DQA/BTLE
trudy.ciszek@dhs.wisconsin.gov
608-266-7881
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Ann Hansen: WWIG Scholarship Recipient
Bureau of Health Services
Twenty-three women working in and with state and local government have
received full scholarships to participate in the 12th Annual Public Policy
Graduate Seminar program, Wisconsin Women in Government (WWIG). The
six-week course, offered in cooperation with the La Follette Institute of
Public Affairs at UW-Madison, ran from January to February. Ann Hansen, a
QAPS-Senior in the Bureau of Health Services (BHS), is a recipient of one
of the scholarships.
Scholarship recipients take part in this management and leadership
training which is specifically tailored for those who either work in state
government or who interact with state government as part of their jobs in
the private sector.
The Graduate Seminar is a program fully funded by Wisconsin Women in
Government (WWIG) and offered in cooperation with the La Follette School
of Public Affairs. It is funded through an annual banquet fundraiser, held
every spring, and attended by 1,000 state and local elected officials,
business leaders, public servants, and political enthusiasts.
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New ADRCs
Administrator's Office
Since January, the following counties have established ADRCs: Adams,
Kewaunee, Marinette, Menominee, Oconto, Oneida, Shawano, Taylor, and
Vilas.
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WISCONSIN NURSE AIDE OUT-OF-STATE TRANSFER PROCESS
Office of Caregiver Quality
Transferring a nurse aide status from another state's Nurse Aide
Registry to the Wisconsin Nurse Aide Registry?
Only nurse aides who have completed a training program of 120 hours or
more that includes a minimum of 32 hours of clinical training are eligible
to transfer to Wisconsin's Nurse Aide Registry. You may access the
Registry Out-of-State Application form via: http://www.pearsonvue.com
To complete this process, the transferring aide completes Part I of the
Registry Out-Of-State Application and attaches verification of
their personal identity, including:
- Name
- Date of Birth
- Social Security Number
- A copy of their training certificate of completion or official
transcript indicating completion of at least 120 hours of training
with 32 hours of clinical.
The completed form is then mailed to the Nurse Aide Registry in the
state where the nurse aide is currently listed. You can find the address
and phone number of each state's nurse aide registry via: http://www.pearsonvue.com
Nurse aide registry personnel in that state will complete Part II of
the application, verifying the individual's status in that state. The
other state will then mail the completed application to Wisconsin.
Wisconsin registry staff will then process the out-of-state application
and the applicant will be notified by mail whether they were or were not
placed on the Wisconsin Registry.
PLEASE NOTE: Nurse aides transferring from another
state may not provide "hands on" care in a facility in Wisconsin
until they have been placed on the Wisconsin Nurse Aide Registry. The
provision in 146.40(2)(c) which allows an individual to be employed as a
nurse aide for fewer than 120 calendar days does not apply to individuals
who are already listed on another state's registry and wish to transfer to
Wisconsin.
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DQA Implements New Provider Search Application
Bureau of Technology, Licensing and Education
The Division of Quality Assurance is pleased to announce a new online
Provider Search application that is scheduled to be implemented in April,
2012. This application supplements the provider directories that DQA has
posted on its website for several years and will give users the ability to
create lists of providers that meet their specific needs.
This Internet-based application will include all provider types
regulated by DQA and will allow consumers to locate providers they are
interested in by entering geographic and other search criteria. Users may
identify specific types of health care providers, a provider's name, a
specific county, city, zip code, or distance from a zip code. Users
interested in assisted living facilities can also search for providers
licensed to serve specific client groups. All providers matching a user's
search criteria will display in a list, along with a Google map
identifying their location. Users may then select a specific provider and
obtain additional information, including the provider's name, address,
telephone number, licensure and/or certification type, ownership
information, and a link to driving directions. Beginning in July 2012,
this information will be supplemented with links to provider-specific
survey reports issued by DQA and related sources of information on
providers' performance.
When the Provider Search application becomes available, it may be
accessed on the DQA website at:
http://www.dhs.wisconsin.gov/bqaconsumer/search.htm
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Listen, Act and Live!
ReadyWisconsin Launches Tornado Awareness Campaign
With Wisconsin suddenly thrust into spring (or summer for some parts of
the state) ReadyWisconsin thought it would be a good idea to get their
Tornado and Severe Weather Awareness Week materials out to us a little
early this year. Tornado and Severe Weather Awareness Week is April 16-20.
The statewide
tornado drill is scheduled for Thursday, April 19th. The statewide mock
tornado watch will be issued at 1 pm, with the statewide mock tornado
warning at 1:45 pm. This is the first time that the warning will be issued
statewide rather than by weather office service areas. Also for the first
time, radio, TV, and cable stations will participate in the drill. See
this link for more information:
http://readywisconsin.wi.gov/tornado/Tornado%202012%20Drill%20Info%20Sheet.pdf
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UPCOMING EVENTS
FOCUS 2012
The Department of Health Services is pleased to announce the 11th
Annual Conference for Health Care Providers and Division of Quality
Assurance Staff.
The Special Session is scheduled for Wednesday, November 28, and is
entitled "The Art and Science of Fall Prevention." This session
is designed to address such issues as risk management, developing a
culture of safety, environmental factors, effects of medications, and
exercise programs. The Conference --- "Mission Possible" ---
occurs on Thursday, November 29, and offers learning opportunities in the
areas of assessment of altered hydration status, meeting culturally
diverse needs, infection control surveillance, person-centered research,
nurse delegation, new dining standards, delirium, oral care, and more.
This year's conference will be held at the Kalahari Convention Center
in Wisconsin Dells. A full conference brochure and conference registration
will be available on line in mid-August. For more information, go to:
http://www.uwsp.edu/conted/ConfWrkShp/Pages/Focus2012.aspx
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REGULAR FEATURES
Changes in DQA Staff
Office of Caregiver Quality
Laurie Arkens- Promotion
Director / Office of Caregiver Quality
Laurie Arkens, Assisted Living Regional Director of the
Bureau of Assisted Living Northeast Regional Office, was promoted to the
Director of the Office of Caregiver Quality within DQA. Laurie was a
member of the original management team when BAL first became a Section.
Her leadership and hard work led to a number of innovative initiatives
that have helped BAL become an effective and efficient regulatory agency
receiving national acclaim.
In her new role, Laurie is responsible for
overall statewide oversight of the Caregiver Law requirements, including
background checks and misconduct investigations, as well as federal and
state nurse aide training, testing, and registry requirements. Laurie
assumed her new responsibilities February 27th. Laurie will continue to
assist BAL/NERO during the transition to a replacement regional director.
She splits her time between DQA's central office in Madison and the
regional office in DePere.
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Bill Gardner- New Employee
ALRD/ Bureau of Assisted Living (WRO)
Bill Gardner joined the Bureau of Assisted Living (BAL) effective
February 13, 2012, as the Assisted Living Regional Director in the Western
(Eau Claire) Regional Office. This position was formerly held by Susan
Murphy who retired in December 2011.
Bill comes to BAL from the Department of Children and Families where he
held the position of Licensing Chief in the Western Region since 2006. In
his role as Licensing Chief, Bill supervised eight licensing specialists
and three administrative support staff. His experience in supervision,
enforcement of licensing rules and standards, and effectively coordinating
complaint investigations will be an asset to our Division/Bureau. Bill is
also an attorney licensed to practice law in both Wisconsin and Minnesota
and was previously employed with the Piper Jaffray Company, Gardner and
Gardner Law Firm, and Wausau Insurance Companies.
Nikki Andrews - New Employee
Quality Assurance Program Specialist - Senior / Bureau of Assisted
Living (SERO)
Nikki Andrews will be joining the Bureau of Assisted Living as the
Quality Assurance Program Specialist - Senior position in SERO. Nikki has
worked for Dungarvin Wisconsin --- a large assisted living provider ---
since 2003, holding a number of different positions. For the last five
years she has served in the capacity of Area Director for both the
LaCrosse and Milwaukee areas. Nikki obtained her Bachelor of Science
degree from University of Wisconsin - LaCrosse. Nikki begins her position
on April 23, 2012.
Update regarding Bureau of Assisted Living SERO
Carolyn Happel, Assisted Living Regional Director for the Southeast
Regional Office, will be on an extended medical leave and Kevin Coughlin
will be acting Regional Director for SERO. Please keep Carolyn in your
thoughts and prayers during her recovery period.
Gina Bertolini - Promotion
Records and Forms Management Specialist / Bureau of Technology,
Licensing, and Education
Gina Bertolini has been promoted to the position of Records and Forms
Management Specialist in the Information Management Section, Bureau of
Technology, Licensing, and Education. Gina has served as an Operations
Program Associate in BTLE since 2007 and in that capacity has been
responsible for the development of forms and publications, among many
other duties. Prior to joining DQA Gina held related positions in the
Division of Disability and Elder Services and the State Vital Records
Office.
In her new role, Gina will be responsible for overall management of
DQA's records and files, response to records requests under the state's
Open Records Law, and oversight of the Division's forms/publications
program. She will also assist with the planned development of DQA's
electronic records management system. Gina assumed her new
responsibilities beginning March 12. She is based at DQA's central office
in Madison.
Sherry Walters - Transfer
Research Analyst / Bureau of Technology, Licensing, and Education
Sherry Walters has been appointed to the Research Analyst Advanced
position in the Information Management Section, Bureau of Technology,
Licensing and Education. Sherry has served as Assistant to the Regional
Field Operations Director in DQA's Western Regional Office since 1997.
Prior to that, Sherry held positions as a management information
specialist at UW-Eau Claire and as a program assistant in the Western
Regional Office.
In her new position, Sherry will serve as the first-level administrator
of DQA's enterprise survey data system (ASPEN), providing system
administration, staff training and technical support, and liaison with CMS
and its contractors regarding system operations. She will also assume
primary responsibility for the development and maintenance of management
information reports DQA relies on and will be responsible for production
of DQA's annual Consumer Information Report and liaison with facilities
submitting the nursing home staffing data that is used to produce it.
Sherry assumed her new position March 26. She will be based in DQA's
Western Regional Office (Eau Claire).
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DQA Numbered Memos (January, February, March)
Access these memos via
http://www.dhs.wisconsin.gov/rl_DSL/Publications/BQAnodMems.htm
or via individual providers' publications pages at
http://www.dhs.wisconsin.gov/rl_DSL/
|
Memo No. |
Title |
Summary |
Providers |
| 12-01 |
CMS S & C Memo 11-35 Mandate of Section 6121 of
the Affordable Care Act for Nurse Aide Training in Nursing Homes |
CMS Survey and Certification (S&C) Memo 11-35
reports on the progress of a project mandated by Section 6121 of
the Affordable Care Act to enhance the skills of nurse aides in
two important areas ---caring for residents with dementia and
preventing resident abuse. |
Nursing Homes
Nurse Aide Training Programs |
| 12-02 |
Prevention of Urinary Tract Infections Use of a
Catheter - Standard of Practice Resource |
DQA has developed the Standard of Practice Resource,
Use of a Catheter (F315), for nursing homes to promote high
performance standards, good resident outcomes, and to understand
the federal requirements regarding prevention of urinary tract
infections. |
Nursing Homes |
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CMS Survey & Certification Letters (January,
February, March)
Listed below are Survey and Certification (S&C)
Letters distributed by the Centers for Medicare & Medicaid Services
(CMS) during the last quarter. Please note that the CMS Internet site for
reviewing all S&C memos is:
http://www.cms.hhs.gov/SurveyCertificationGenInfo/PMSR/list.asp
| S&C No. |
Title |
Summary |
Providers Affected |
| 12-08 |
Federal Requirements for the Independent Informal
Dispute Resolution (Independent IDR) Process for Federal
Requirements for the IIDR Process for Nursing Homes |
This memo replaces S&C Memo 12-02-NH dated
October 14, 2011, which discusses Federal requirements for the
Independent IDR process for nursing homes. Please disregard the
October 14, 2011 version. This memorandum provides interim
advanced guidance |
Nursing Homes |
| 12-09 |
Certificate and Regulatory Multiple Site Exceptions
under CLIA |
Additional clarification and guidance is given for
certifying laboratories under the various regulatory multiple
sites exceptions. |
CLIA |
| 12-10 |
Affordable Care Act and Implications for
Certification of Physician-owned Hospitals |
The Affordable Care Act prohibits the referral of
Medicare beneficiaries by physician owners or investors to new
PoHs or to existing PoHs that have expanded their facility
capacity beyond their baseline. An exceptions process allows some
PoHs, which meet specific criteria, to expand after the baseline
date. The statutory prohibition applies to physician owner
referral and hospital billing activity. |
Hospital/CAH |
| 12-11 |
Notice - Fifth Opportunity National Background Check
Program Funding |
CMS released a fifth solicitation for the National
Background Check Program (NBCP) for any States or U.S. Territories
that were unable to meet the previous deadline for submitting
their applications under the previous solicitation. Applications
are due February 28, 2012. |
Nursing Homes |
| 12-12 |
Prudent Action for the FY 2012 Medicare Survey and
Certification Budget |
It is prudent to prepare now for a lower FY2012
funding level than previously expected. CMS and States have worked
to develop a variety of methods to increase efficiency and
effectiveness. While these efforts may not entirely address the
difference between the requested and likely budget levels, they
will mitigate negative effects. Additional efforts will be
necessary, and expectations for FY2012 funding will need to be
adjusted. |
All |
| 12-13 |
Use of Federally Imposed Civil Money Penalty (CMP)
Funds by States |
Update Supersedes S&C: 11-42-NH. Beginning
January 1, 2012, States must obtain prior approval from CMS for
the use of federally imposed CMP funds. |
Nursing Homes |
| 12-14 |
Home Health Survey and Certification Activities
Related to Program |
The Home Health Prospective Payment System (PPS)
final rule, CMS 1510-F, amended the regulations for HHA
certification. HHAs that undergo a change in majority ownership
within three years of initial Medicare enrollment or within three
years of a previous change in majority ownership must enroll in
the Medicare program as a new HHA, and obtain a new State survey
or deemed status accreditation. |
Home Health Agencies |
| 12-15 |
Revised Initial Certification Process for Home
Health Agencies |
This memo revises the current process for initial
certification of prospective HHAs. An additional step is added to
accommodate a second review of enrollment criteria performed by
the Regional Home Health Intermediary (RHHI) or Medicare
Administrative Contractor (MAC). |
Home Health Agencies |
| 12-16 |
Survey and Certification Responsibilities Related to
Provider Enrollment Revocations |
This memo outlines the responsibilities of the
Regional Office (RO) when the Medicare Administrative
Contractor/Fiscal Intermediary issues a notice of revocation to a
provider. |
All |
| 12-17 |
Referring Practitioners Ordering Outpatient Services
in Hospitals |
Outpatient services in hospitals may be ordered (and
patients may be referred for hospital outpatient services) by a
practitioner who is responsible for the care of the patient;
licensed in, or holds a license recognized in the jurisdiction
where he/she sees the patient; acting within his/her scope of
practice under State law; and authorized by the medical staff to
order the applicable outpatient services under a written hospital
policy that is approved by the governing body. This includes both
practitioners who are on the hospital medical staff and who hold
medical staff privileges that include ordering the services, as
well as other practitioners who are not on the hospital medical
staff, but who satisfy the hospital's policies for ordering
applicable outpatient services and for referring patients for
hospital outpatient services. |
Hospitals |
| 12-18 |
Hospital Patient Privacy and Medical Record
Confidentiality |
Guidance concerning the protection of patient
privacy and medical record information is clarified. This guidance
is consistent with the standards under HIPAA Privacy Rule Guidance
concerning permitted incidental uses and disclosures, is
clarified, and includes reasonable safeguards that must be in
place to ensure patient privacy. Tags A-0441, A-0442 and A-0443
have been combined. |
Hospitals |
| 12-19 |
Living Donor Services Occurring in Transplant
Programs Other than that of the Organ Recipient: Requirements and
Surveyor Guidance |
This letter addresses Medicare requirements for
transplant programs and surveyor activities in which some or all
of the services for a living donor are provided by a program other
than the transplant program of the organ recipient. Finalizes
Interim Guidance, S&C 11-40-Transplant. This memorandum
replaces the interim guidance that was previously released
September 30, 2011. |
Transplant |
| 12-20 |
Implementing the Individualized Quality Control Plan
(IQCP) for Clinical Laboratory Improvement Amendments (CLIA) |
CMS is incorporating into the Interpretive
Guidelines (IG), based on 42 CFR 493.1250, key concepts and
graphics from Clinical and Laboratory Standards Institute (CLSI)
Evaluation Protocol-23 (EP-23), Laboratory Quality Control Based
on Risk Management, as alternative Clinical Laboratory Improvement
Amendment (CLIA) Quality Control (QC) policy. |
CLIA |
| 12-21 |
Instructions Concerning Waivers of Specific
Requirements of the 2012 Edition of the National Fire Protection
Association (NFPA) 101, the Life Safety Code (LSC), in Health Care
Facilities - Clarification Effective Immediately |
This letter addresses updates to the CMS policy
regarding Capacity of the Means of Egress, Cooking Facilities,
Heating, Ventilating, and Air Conditioning, and Furnishings,
Mattresses, and Decorations. |
LSC |
| 12-22 |
Healthcare Associated Infections (HAI) Prevention
Program Environmental Scan of State Survey Agency |
CMS, in collaboration with the CDC, will conduct a
Healthcare Associated Infections Prevention Program Environmental
Scan of State Survey Agency Training Coordinators and State HAI
Coordinators. |
Nursing Home |
| 12-23 |
INFORMATION: Reducing Avoidable Hospitalizations
among Nursing Facility Residents; State Survey |
On Thursday March 15, 2012, CMS announced the
Initiative to Reduce Avoidable Hospitalizations among Nursing
Facility Residents, a new effort designed to improve care for
people living in nursing facilities who are enrolled in Medicare
and Medicaid. |
All |
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Publication Contact: Gina Bertolini
E-Mail: Gina.Bertolini@dhs.wisconsin.gov
Phone: (608) 266-6691
MAIL SUBSCRIPTION SERVICES
http://www.dhs.wisconsin.gov/rl_DSL/Listserv/signup.HTM
Last Revised:
February 06, 2013
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