The long-awaited regulations for Quality Assurance and Performance Improvement (QAPI) are included in the proposed Medicare and Medicaid Programs: Reform of Requirements for Long Term Care Facilities released by the Centers for Medicare & Medicaid Services (CMS) two weeks ago. Members will be required to develop, implement and maintain an effective, comprehensive, data-driven QAPI program addressing outcomes of care and quality of life indicators.
Included in expectations will be training of all staff on the elements and goals of the QAPI program and how the organization intends to implement and monitor the program including:
- Focus the Quality Assessment and Assurance Committee on systems of care and management practices and always include clinical care, quality of life, choices for residents, and desired outcomes for residents reflective of the complexities, unique care and services provided.
- Incorporate a process with effective systems to obtain and use input from direct care workers and other staff, residents, resident representatives and families to identify opportunities for improvement.
- Ensure systems are in place to identify, collect, and use data from all departments to identify high risk, high volume or problem-prone areas.
- Include a process for identifying, reporting, analyzing and preventing adverse events and potential adverse events.
- Establish a process to determine underlying causes of problems such as root cause analysis, reverse tracer methodology, and failure and effects analysis.
- Monitor and evaluate performance of all services and programs including services under contract arrangement.
- Ensure the program is defined, implemented, maintained and addresses identified priorities and is adequately resourced with staff time, equipment and technical training as needed.
- Quality Assessment and Assurance Committee membership does not change, but should be noted that it is a minimum and the facility may have additional participants.
- Maintain documentation and demonstrate evidence of the QAPI program.
- Submit the QAPI plan to state or federal surveyor at the first annual recertification survey and present to state agency surveyor at each annual recertification survey or upon request.
CMS generally implements changes to regulatory requirements for survey and certification processes within 12 months of the final rule publication. It is believed disclosure of QAPI committee records, except to ensure the committee is in compliance with regulation and attempts to identify and correct quality issues, will not be used as the basis for sanctions.
It is highly recommended your organization’s Quality Assessment and Assurance Committee read the full reform requirements for long term care and review how many recommendations should be on the radar for detailed monitoring in the following areas: resident assessments, person-centered care planning, infection control, quality of care and quality of life, physician services, nursing services related to staffing, pharmacy services, behavioral services, dental services, food and nutrition, ethics program, and physical environment.
Technical assistance is available to nursing homes here. This includes assistance on developing best practices related to QAPI through tools regarding the five elements: 1) Design and Scope, 2) Governance and Leadership, 3) Feedback, Data Systems and Monitoring, 4) Performance Improvement Projects and 5) Systematic Analysis and Systemic Action.