CMS Hospital Improvement Rules; Nursing, Medical Records, Infection Control, Antibiotic Stewardship Program, Restraints, QAPI, and more

CMS made some significant changes to the hospital conditions of participation (CoPs) that every hospital should know, including critical access hospitals. It was over 600 pages long and combined three laws into one. This includes changes to nursing, medical records, infection control, QAPI, patient rights, H&Ps, and restraint and seclusion.  The effective date was November 29, 2019.  However Critical Access Hospitals have until the end of March 2021 to implement a QAPI program since their QAPI requirements were completely written.

The new rules require all hospitals to have an antibiotic stewardship program and what the program should include. The CDC revised the core elements in November of 2019. Also, a great part of this document included things that CMS has found to be problematic in hospitals that are already a requirement in the hospital CoPs. CMS also clarified a number of existing requirements and a number of federal regulations that are already final which makes this webinar an excellent resource.

• Recall that hospitals have requirements in the CMS CoPs on an antimicrobial stewardship program
• Discuss that CMS change  the term LIP (licensed independent practitioner) to LP (licensed practitioner) so PAs can order restraint and seclusion and do assessments if allowed by the hospital
• Describe that the hospital must have policies that describe which outpatient areas require an RN
• Recall CMS removed the section that required hospitals to conduct autopsies in cases of unusual deaths.

Introduction

• Interpretive guidelines and survey procedures to be issued
• How to get a copy of the CoP manual, survey memos, etc.
• Why revise the CoPs

Psychiatric Hospitals

• Non-physicians writing in progress notes
• How often progress notes must be written

Emergency Preparedness

• Staff training every two years
• Exercises twice a year
• EP policies and procedures
• Emergency plan

H&P Changes

• When is an H&P required?
• Assessments instead in healthy outpatients
• Medical staff policy requirements
• Considerations

Patient Rights and Medical Records

• Restraint  changes
• Change from LIP to the licensed practitioner (LP)
• Physician Assistants (PAs) to order and evaluate       
• Non-discrimination under OCR 1557
  • Written policy prohibiting
  • Inform each patient on the prohibition against discrimination
  • Inform on how to file a complaint
  • Currently, already law and CMS decides NOT to include in the CoPs
• The Medical Records section was not implemented
  • Content of medical records
  • Document complications and hospital-acquired conditions
  • Diagnosis in the outpatient record in 7 days
  • Discharge instructions and transfer summaries

QAPI

• Quality indicator data including patient care data
• Medicare Quality Reporting Data
• Hospital readmission data
• Hospital-acquired conditions (HACs) and 5 changes

Nursing Services and Outpatient Departments

• Staffing-adequate number
• Supervisory staff
• Need to respond immediately when needed
• Nursing care plans
• Policies and procedures
• CNO must evaluate nursing staff including agency staff
• All outpatient departments must identify if RN must be present
• Outpatient policy required
• P&P must be reviewed by MEC
• Orders for drugs and biologicals
• Verbal  orders

Look Back Program and the Lab

• Notification of tainted blood
• Patient notification process
• The time frame for notification

Autopsies

• The deleted requirement to get in unusual cases
• Coroner cases

Four swing bed changes

• Dental
• Activity program and assessment and plan of care
• Social worker
• Residents performing services

Infection Control and Antibiotic Stewardship

• Hospital-wide surveillance
• CDC outpatient assessment tools
• Following nationally recognized standards and best practices
• Infection control hospital-wide QAPI program
• Infection control program and policies requirements
• Qualified infection preventionist
• Requirements for the antibiotic stewardship program
  • The qualified leader who must be appointed by the board
  • Active program and evidenced-based use of antibiotics
  • Document improvements and reduction of CDI
  • Board responsibilities
  • Responsibilities of the leader of the antibiotic stewardship program
• Antibiotic stewardship policies
• Tracking all infections
• QAPI leadership
• Competency-based staff training

Pharmacist, chief nursing officer, health information management, infection preventionist, antimicrobial stewardship team members, nurses, nurse educators, chief medical officer, QAPI director and staff, patient safety officers, regulatory and compliance officers, physician assistants (PAs),  patient advocate, risk management, nurse educators, hospital legal counsel, MEC chair, board members, and anyone involved in implementing the hospitals' CoPs.