As part of the Phase 2 rollout of the Mega Rule, nursing homes that participate in the Medicare and/or Medicaid programs must provide residents (and their representatives when applicable) with a baseline care plan summary starting Nov. 28, 2017. The Centers for Medicare & Medicaid Services (CMS) laid out the approach surveyors will take toward assessing compliance in the recently released advance copy of Appendix PP, “Guidance to Surveyors for Long-term Care Facilities,” of the State Operations Manual.
The interpretive guidance for F-tag 655 (baseline care plans) contains some surprises. For example, many providers had previously assumed that the baseline care plan summary would need to be provided to residents/representatives within the same 48-hour window as the baseline care plan. However, CMS provides leeway, allowing nursing homes until the completion of the comprehensive care plan to deliver this summary. In addition, while providers do have to provide a written summary, they are allowed to use the baseline care plan as the summary if it meets all of the summary requirements. (For more information about all of the requirements, see the summary checklist at the end of this article.)
“Nurse assessment coordinators (NACs) can play a key role in deciding what the baseline care plan summary looks like,” suggests Robin Hillier, CPA, STNA, LNHA, RAC-MT, president of RLH Consulting in Westerville, OH. “Does the facility want to provide a copy of the baseline care plan itself? If so, how can it be made compliant with the summary requirements? If not, how will you pull in the various pieces done by the interdisciplinary team to make this summary easy for the resident and their family to understand what the team is doing?”
In addition, NACs should help their facilities determine who is providing the summary to the resident/family, exactly when that will occur, and what the process will be for handling updates, advises Judy Wilhide Brandt, RN, BA, QCP, CPC, RAC-MT, DNS-CT, principal of Wilhide Consulting in Virginia Beach, VA. “I suspect the MDS coordinator may be on the team to present the summary to the resident or representative.”
The following baseline care plan summary checklist was adapted from F655 in Appendix PP:
The facility must provide:
- To Whom: The resident and the representative, if applicable;
- What: A written summary of the baseline care plan, written in a language and conveyed in a manner the resident and/or representative can understand; and
- When: By completion of the comprehensive care plan.
Minimum summary content:
- Initial goals for the resident;
- A list of current medications and dietary instructions, and
- Services and treatments to be administered by the facility and personnel acting on behalf of the facility;
- The format and location of the summary is at the facility’s discretion; and
- The facility may choose to provide a copy of the baseline care plan itself as the summary, as long as it meets all of the requirements of the summary.
Additional summary requirements:
- The medical record must contain evidence that the summary was given to the resident and resident representative, if applicable.
- Any updated information based on details of the admission comprehensive assessment. If the comprehensive assessment and comprehensive care plan identified a change in the resident’s goals, or physical, mental, or psychosocial functioning, which was otherwise not identified in the baseline care plan, those changes must be incorporated into an updated summary provided to the resident and his or her representative, if applicable.
Note: Once the comprehensive care plan has been developed and implemented, and a summary of the updates given to the resident, the facility is no longer required to revise/update the written summary of the baseline care plan. Rather, each resident will remain actively engaged in his or her care planning process through the resident’s rights to participate in the development of, and be informed in advance of changes to the care plan.
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Reviewed March 6, 2020