CMS recently released new guidance for nursing home surveyors regarding 11 F-tags, many of which focus on the quality of life provided to nursing home residents. The guidance, which can be found in Appendix PP, Guidance for Surveyors, of the State Operations Manual, went into effect June 12.
The quality of life F-tags were originally adopted in 1991. "However, some of the regulatory language of these F-tags was very general, leaving providers and surveyors on their own to determine what the regulations actually meant," says Karen C. Schoeneman, MPA, deputy director of CMS' division of nursing homes. "The new guidance will make sure everyone is on the same page."
The new guidance provides further clarification and revises the interpretive guidelines for the following F-tags:
- F172 Access and Visitation Rights
- F175 Married Couples
- F241 Dignity
- F242 Self-Determination and Participation
- F246 Accommodation of Needs
- F247 Notice Before Room or Roommate Change
- F252 Safe, Clean, Comfortable and Homelike Environment
- F256 Adequate and Comfortable Lighting
- F371 Sanitary Conditions
- F461 Resident Rooms
- F463 Resident Call System
"If your facility does not comply with these F-tags, you can expect to receive deficiencies during your next survey," Schoeneman says.
Implementing all the practices outlined in the new guidance may seem like a daunting task but, fortunately, there are some simple things nursing facilities can do to work toward compliance. For example, facilities can ensure adequate lighting, F256, by using daylight as much as possible and adding table or floor lamps where light is insufficient. Facilities can address the revised guidance for F246, Accommodation of Needs, by individualizing residents' physical environments. For example, staff members can adjust door handles, mirrors, closet rods, and other items in the resident's room and bathroom to better suit the resident's needs.
Although there are simple solutions to help facilities comply with some of the new guidance, complying with other components will not be as easy. The revised guidance for F242, Self-Determination and Participation, clarifies that residents have the right to make choices about things that are important to him or her, such as method of bathing and schedules. In the majority of nursing homes, residents follow the schedule of the facility, not their own. Changing this will be a challenge.
The new guidance for F252, Environment, says that all facilities should work to decrease the institutional character of the environment and can do so by eliminating certain features, such as nursing stations, medication carts, and audible chair and bed alarms. However, unlike other components of the new guidance, a facility will not be considered non-compliant if they still have some of the institutional features.
"The guidelines for F252 include a caveat, or softening sentence, saying that many facilities may not be able to immediately address all of the issues, but they should work toward the changes," Schoeneman says. "Decreasing the institutional character of nursing homes is our vision for the future and, by including this language into the new guidance, we are hoping to point providers in the right direction."