Transforming CMS Guidelines into an SNF Handbook

The Centers for Medicare & Medicaid Services (CMS) announced in July that it would change the way it evaluates skilled nursing facilities (SNFs), now focusing on four measures instead of one. Since October 1, SNFs across the country have been evaluated based on their 30-day hospital readmission rates, number of hospital-acquired infections, overall nursing staffing levels and staff turnover. Poor assessment results could result in penalties or reduced incentives. CMS also noted that the Perspective Payment System (PPS) base rate would increase by 3.2%.

These changes put skilled nursing facilities even more in the spotlight than they already are and add even more pressure, forcing outcomes and workforce stability to be a critical part of how CMS determines its value-based incentive payments for care. Given that staffing and turnover can have a significant impact on patient outcomes and hospital readmissions, these updated guidelines provide a good opportunity for SNFs to change the way they operate in the future. Those who soon start implementing new policies and goals and start operating as one system, rather than prioritizing each outcome separately, will be the ones to achieve the best results.

Change operations to make a difference

No organization or facility, large or small, can completely change the way it operates overnight. It can often take months or even years for new processes to be decided, shared with teams and officially deployed. Unfortunately, the time SNFs have to make these changes is limited. Here are three processes SNF leaders should immediately implement into their workflows to initiate organizational change.

1. Make readmission prevention a priority and a daily habit. Online platforms such as electronic medical records and the additional tools that accompany them can be an important resource in preventing readmission and should be leveraged frequently by SNFs. AI within these platforms can be used to analyze provider progress notes, vital signs, labs, medications, medication regimens, and social work notes to automatically flag patients who are at risk of being readmitted or showing early signs of deterioration, allowing them to be monitored more closely. Patients recently admitted to the SNF, those with underlying conditions such as COPD, and anyone whose health has deteriorated significantly in the past week should also be marked as high risk and closely monitored. Additionally, effectively coordinated management of out-of-facility transitions is essential to reduce the risk of readmission after discharge. SNF staff should confirm with patients and primary care physicians that a follow-up appointment is scheduled shortly after discharge to ensure there are no further complications. SNF staff should also conduct at least one virtual check-in with patients within 48 hours of discharge to check on their symptoms and ensure that remote monitoring tools, if used, are working effectively.
2. Consider infection management as a readmission measure. Patients admitted to facilities are often vulnerable to infection, particularly those who cannot move around alone. Regularly checking for signs of urinary tract infections, pneumonia and wound deterioration can allow staff to provide effective interventions before infections put the patient at risk. Staff should closely monitor all medical devices or tools such as central lines or urinary catheters and remove them promptly if they are no longer needed. Should an infection occur, it is essential that SNF staff have direct access to an on-site medical director or nurse practitioner for same-day evaluation to quickly prescribe necessary medications and avoid hospital readmission.
3. Stabilize the workforce to stabilize the results. Unfortunately, many SNFs will see most of their preventable events occur during nights and weekends, often when most team members are not on duty. Leaders should optimize their staffing by first using their most efficient and experienced staff during these shifts, then building the rest of the schedule around that. Human resources and other facility leaders also need to leverage data and feedback to retain staff. While exit interviews can provide insight into what went wrong during an employee’s time with the company, regular check-ins can provide real-time feedback and are far more beneficial. These informal conversations can take place as often as monthly, or even quarterly, and can provide management teams with insight into workloads and schedules, helping to detect burnout or any declines in job satisfaction before they lead to turnover.

While these new CMS guidelines may seem overwhelming at first for SNF leaders, they could serve as motivation to improve efficiency at all levels. CMS does not require skilled nursing facilities to be perfect. There will always be unavoidable events, even with the best staff available, but making the effort to implement small changes in daily practices will go a long way. Prioritizing readmissions and patient outcomes while ensuring employee satisfaction will not only help comply with CMS assessment guidelines, but will ultimately lead to better outcomes for the organization and its patients.

Photo: Wavebreakmedia, Getty Images

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