Effective last November, CMS implemented new guidance to surveyors for long-term care facilities. The interpretive guidelines refer to the categories as “Ftags.[1]” The administration and clinical staff of nursing homes, as well as surveyors, defense and insurance groups for the facilities, and attorneys working for plaintiffs all need to be familiar with the interpretive guidelines now in place. ALN Consulting legal nurses are experts in the changes in CMS guidance and are happy to share our knowledge to improve patient care in long-term care facilities.

F655, “Baseline Care Plan” had no associated tag in the old guidance. The CFR regulations pertaining to this Ftag are §483.21 (a)(1) -(3).  The most important guidance in this Ftag is that the facility must develop and implement a baseline care plan for each resident within 48 hours of a resident’s admission. The baseline care plan must include the minimum healthcare information necessary to properly care for a resident including, but not limited to:

  • Initial goals based on admission orders
  • Physician orders
  • Dietary orders
  • Therapy services
  • Social Services
  • PASARR recommendations (if applicable)

The facility must provide the resident and their representative with a summary of the baseline care plan that includes but is not limited to: the initial goals of the resident; a summary of medications and dietary instructions; any services and treatments to be administered; and any updated information based on the details of the comprehensive care plan, as necessary.

The new F656, “Develop/Implement Comprehensive Care Plan” was known as Ftag 279 prior to the November 2017 update. The CFR regulations pertaining to this Ftag are §483.21 (b)(1). The guidance in F656 states a long-term care facility must develop and implement a comprehensive, “person-centered” care plan for each resident consistent with the resident’s rights that includes measurable objectives and timeframes to meet the needs identified in the comprehensive assessment. Important to note, “although Federal requirements dictate the completion of RAI assessments according to certain time frames, standards of good clinical practice dictate that the clinical assessment process is more fluid and should be ongoing.” Resident preferences and goals should be evident in the comprehensive care plan.

Finally, F657, “Care Plan Timing and Revision” was known as Ftag 280 in previous versions of the interpretive guidelines. The CFR regulations pertaining to this Ftag are §483.21 (b)(2)(i)-(iii). As with prior guidance, the comprehensive care plan must be developed within seven days after completion of the comprehensive assessment. In addition to preparation by an interdisciplinary team that includes the attending physician, an RN with responsibility for the resident, and participation of the resident, additionally, now, input by a nurse aid, a member of the food and nutrition services staff, and the resident’s representative is now included in the guidance. The care plan must be revised after each Resident Assessment Instrument (RAI) or Minimum Data Set (MDS) assessments, except for discharge assessments. It must also be completed no more than 21 days after the admission.

ALN Consulting’s expert legal nurse consultants stay abreast of all of the regulatory and compliance changes in the long-term care field so that their clients always have the most current and accurate reviews. The ALN Consulting team is a leading provider of medical-legal consulting services nationwide. Contact us today to add our expertise to your next case.

[1] https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/GuidanceforLawsAndRegulations/Downloads/Appendix-PP-State-Operations-Manual.pdf