This week's “F-Tags in Review” focuses on F607 – Development and Implementation of Policies for the Prevention, Identification and Training on Abuse and Neglect of Residents. This regulation was identified and implemented in the November 2018 Phase II of the Centers for Medicare and Medicaid Services’ roll-out of new survey procedures.
The intent of this regulation is
“…to provide protections for the health, welfare and rights of each resident residing in the facility. In order to provide these protections, the facility must develop written policies and procedures to prohibit and prevent abuse, neglect, exploitation of residents, and misappropriation of resident property.”
These written policies must include, but are not limited to the following components:
Since the roll-out of the new survey process, this regulation has gained a considerable amount of attention—it represents the basis for care delivery within a skilled nursing facility (SNF). This regulation not only enforces the need for regulatory compliance, but it also outlines guiding principles for providing exceptional person-centered care.
Since November 2017, F607 has been cited 238 times across 28 different states. Six states top the list with 9 or more facilities, in each state, receiving citations for this regulation. The top 6 states include: Ohio with 63 locations; Texas with 35 locations; Illinois with 17 locations; California and Michigan tied with 14 locations; and Massachusetts with 12 locations cited. Each of the remaining 22 states reported that less than 9 facilities receiving this citation. Additionally, the highest level of scope and severity for this tag in the identified states was a level L, followed by a K, J, G, F, E and D.
While citations for F607 identify those facilities requiring initial and ongoing education of staff, the term “staff” refers not only to care-giving staff but also medical directors, consultants, contractors, volunteers, students in nurse aide training programs or students from other disciplines who may be fulfilling course requirements in the facility.
Diving deeper into the nuts and bolts of the regulation shows that the guidelines are made up of several components, all of which need to be present to successfully meet the intent of the regulation. Below is an in-depth look at those components:
- Screening : Polices must exist for screening employees for any history of abuse, neglect, exploitation or misappropriation of resident property to prohibit these actions from occurring in the future. Procedures for this process must be clearly spelled out and followed with each prospective employee. Residents must also be screened prior to admission to assure that the current staffing patterns and staff knowledge level are appropriate to provide the care the prospective resident requires, without the possibility of acts of abuse and neglect towards other residents.
- Training: Facility policies must clearly show the process by which new and existing staff are trained on identifying and preventing all forms of abuse and neglect. In addition, training must exist for staff to understand behavioral symptoms which may escalate to potential episodes of abuse towards others. Some of these symptoms may include wandering, aggressive reactions, resisting care, verbal outbursts and difficulty adjusting to new routines. Ongoing training, documentation and supervision of staff is the key here to achieve compliance with the training segment of the regulation.
- Prevention: Policies that are required to meet this portion of the regulation include items such as: establishing a safe environment for residents; identifying, correcting and intervening in situation where abuse and neglect are more likely to occur. Policies must also assure that residents are free from abuse and neglect as evidenced through the facility assessment which would identify necessary resources to maintain an abuse free environment. The care planning process is required to include ongoing interventions for residents that may have behaviors which could end in conflict such as being verbally, physically or sexually aggressive; remove or disturbing other’s property; previous self-injury; those with communication disorders or speak alternate languages, or those who require extensive nursing care. Additionally, each resident must be provided health and safety from visitors, including family members, if they so chose and visitors must be made aware of the process in place to voice concerns without fear of retribution to themselves or the resident.
- Identification: Facility policy must provide staff members with the procedures to identify actions classified as abusive or of property misappropriations. This would include but not be limited to suspicious injuries, sudden changes in behavior like activities, fear or feelings of guilt or shame. Staff members must feel free to report these suspicions without fear of retaliation.
- Investigation: This is an area that requires special consideration by the facility due to the potential sensitive nature of a complaint or incident. Facility policies must include the staff responsible for any investigations, as well as the careful handling of evidence which could ultimately be used in a criminal investigation. Policies must also cover investigation of different types of alleged violations, including how to interview all persons involved or who have knowledge of the incident. Finally, the policy must identify how documentation of the incident will occur, and documentation must be concise but thorough.
- Protection: Within the policy, the facility must have clearly written procedures on how to protect not only the resident(s) identified but all residents within the facility from an identified offender and/or current or future incident(s). This includes immediate response to the incident and preserving the integrity of the investigation, examination of the victim, increased supervision of the victim(s), room or staffing changes needed for protection, protection from retaliation, and the provision of emotional support and/or counseling to the resident(s) as needed.
- Reporting/Response: Facility policy must include direction on immediate reporting to the administrator, state agencies, protective services and any other required agencies such as law enforcement within required timelines. Reporters must also be afforded the opportunity to be free from retaliation. Facilities must also include an analysis of occurrence(s) and determine an underlying root cause of the incident(s). Facilities must also define how care delivery will change in light of the incident(s), training of staff on any changes made and competency of staff’s understanding of the changes. Lastly, there must be identification of the staff responsible for implementation and monitoring, and the expected date of implementation of changes.
While F607 is a complicated and extensive regulation, it governs the basic necessities required in a person-centered care facility, not to mention it accounts for the best interest of residents. After all, residents are not living in your workplace; you have the privilege of working in their home. Be proactive, be complete, be an advocate, and be a first line responder who advocates for the safety and well being of residents you have the privilege of caring for.
For a full list of commonly cited deficiencies, download our latest F-Tags In Review report.
Is your facility in compliance with the new F-Tag requirements? Let LW Consulting, Inc. conduct an operational review to assess your risk of non-compliance. We also provide education, in-service training and mentoring for housekeeping and maintenance personnel.