According to Wikipedia, “Bigfoot, also commonly referred to as Sasquatch, is a large and hairy human-like mythical creature alleged by some to inhabit forests in North America, particularly in the Pacific Northwest.” 

Other sources say that those who claim to have seen Bigfoot describe everything from a large, upright ape to an actual hairy human, sometimes standing over eight feet tall and depicted as powerfully built. 

I have always been fascinated and a bit annoyed at the possibility of Bigfoot. Fascinated because, who doesn’t want Sasquatch to be real, a bit annoyed because I just don’t believe it is. Wikipedia notwithstanding.

Bigfoot sightings

Contrary, however, to the myths and legends surrounding a large hairy beast in the north woods, a Bigfoot of sorts lurks in every certified nursing facility. Exposed by the bright regulatory light of the recently finalized minimum staffing rule, it can no longer hide in the shadows.

The Bigfoot I’m referring to is the facility assessment. Large and imposing in its own right, the facility assessment was initially implemented as part of the sweeping revisions to the state operations manual (SOM) in Phase 2 of the conditions of participation update in 2017.

CMS has made several revisions to the facility assessment requirements in the minimum staffing rule published in the Federal Register on May 10. The official deadline for implementing the revised facility assessment is 90 days after the rule’s publication — that’s August 8, folks. 

According to the final staffing rule, “(The) facility assessments play an important role in ensuring that LTC facilities develop thoughtful, informed staffing plans to meet the needs of their specific residents based on case mix and other factors.” 

Currently, in Appendix PP of the state operations manual, the combined term “facility assessment” can be found no less than 101 times and it integrates into a significant number of the F-tag guidance found there. 

The SOM refers to the facility assessment in this way: “… An assessment of the resident population is the foundation of the facility assessment. It must include an evaluation of diseases, conditions, physical, functional or cognitive status, acuity of the resident population, and any other pertinent information about the residents that may affect and plan for the services the facility must provide (e.g., MDS data…)

Now, that’s a Bigfoot you can believe in.

Sasquatch footprints

Did you see that? Successful assessment of the resident population is dependent on MDS data. Don’t miss that. Foundational to a facility’s determination of the resources that are necessary to care for its unique resident population competently is an accurate MDS.

Fundamentally, the MDS was designed for just this purpose, and it can get lost in the forest of roles that have been added since its inception. The RAI process, or the nursing process, is the part that the MDS will play in the development of the facility assessment. Remember ADPIE (Assess, Diagnose, Plan Implement, Evaluate)? Sounds a lot like the expected outcome of the facility assessment.

Here are some clues to the MDS’ capacity to bolster the facility assessment through the RAI process. These are currently the requirements for identifying the resident population with regard to the facility assessment in the SOM.

The facility assessment must address or include:

1.  Both the number of residents and the facility’s resident capacity;

2.  The care required by the resident population considering the types of diseases, conditions, physical and cognitive disabilities, overall acuity, and other pertinent facts that are present within that population;

3.  The staff competencies that are necessary to provide the level and types of care needed for the resident population;

4.  The physical environment, equipment, services and other physical plant considerations that are necessary to care for this population; and

5.  Any ethnic, cultural or religious factors that may potentially affect the care provided by the facility, including, but not limited to, activities and food and nutrition services.

Keeping track of your resident population with an eye to taming the facility assessment takes us back to the fundamentals. Without them, this Bigfoot could get pretty scary. 

A big beast and then some

The facility assessment is already a daunting task. Yet, in addition to the current SOM requirements, the Centers for Medicare & Medicaid Services has added a few more in the staffing rule. Regarding the revisions to the facility assessment, in a press release, CMS indicated the following:

To ensure that facilities are utilizing the assessment as intended by making thoughtful, person-centered staffing plans, and decisions focused on meeting resident needs, including staffing at levels above the finalized minimums as indicated by resident acuity, CMS is finalizing the following:

1.  Facilities must use evidence-based methods when care planning for their residents, including consideration for those residents with behavioral health needs.

2.  Facilities must use the facility assessment to assess the specific needs of each resident in the facility and to adjust as necessary based on any significant changes in the resident population.

3.  Facilities must include the input of the nursing home leadership, management and direct care staff, and solicit and consider input received from residents, resident representatives and family members.

4.  Facilities are required to develop a staffing plan to maximize recruitment and retention of staff.

Did you hear that? “… Thoughtful, person-centered staffing plans and decisions focused on meeting the resident’s needs.” 

That is what the facility assessment is all about. It really boils down to this. Bigfoot, as frightening as the creature may seem, may just be a big furball looking for someone to be friends with.

It’s all about relationship

The MDS is a powerful tool. It has always been a part of the process that can lead to completing a facility assessment that is accurate, useful, user-friendly and compliant. Who doesn’t want that? 

What has been your relationship to the facility assessment? Have you embraced it? Have you engaged it and allowed it to direct you as it was intended? Or have you let Bigfoot be the solitary mythical creature that just seems too intimidating to contend with and which you hope the next survey team will ignore as well? 

It’s time to get friendly with the Bigfoot in your facility that may have been hiding in the shadows. Are you ready? This beast is real and really required in less than 90 days. 

Believe it or not.

Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation. For further inquiries, he may be contacted here.

The opinions expressed in McKnight’s Long-Term Care News guest submissions are the author’s and are not necessarily those of McKnight’s Long-Term Care News or its editors.

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