It is clear that better education is the key to marrying culture change and
regulations. Here are some resources that may help bridge the gap for regulators
and nursing home staff. We've included some Action Pact learning tools as well as
other websites with helpful information and stories.
Don't Blame OBRA: The Regulations Aren't in the Way
by Karen Schoeneman
From the website of Almost Home, a feature length documentary chronicling a year
in the life of residents and staff at St. John's retirement community as the
facility and those who live and work there undergo culture change from a medical
model to a social model. This story is one of several posted on the site covering
many aspects of culture change. There is also an eight minute video clip from the
movie about St. John's state survey and how the staff and regulators balance
quality of care with quality of life.
American Health Care Association
This link lists states and has a link to each state's regulations. Simple, to
the point and handy.
From the home page: "AHCA represents the long-term care community to the nation
at large - to government, business leaders, and the general public. It also serves
as a force for change within the long term care field, providing information,
education, and administrative tools that enhance quality at every level."
Medicare
From the U.S. Department of Health and Human Services, this is where you can get
the word right from the horse's mouth. While this page is designed for people with
Medicare, it offers a nice description of the regulation's process and role. This
might be a good place to start when having a discussion about regulations so that
everyone is coming from the same place of this shared knowledge instead of holding
misconceptions or misinformation.
The Pioneer Network
The Pioneer Network offers some articles on different aspects of regulations, an
introduction of the website that compares state regulations in nursing homes
compiled by the University of Minnesota (described in detail in the first of our
trilogy of web stories on regulations) and a a six minute video clip featuring a
discussion between Karen Schoeneman of the CMS Division of Nursing Homes and Thomas
Hamilton, Director of the Survey and Certification Group at CMS. They discuss how
person-directed care is consistent with existing federal regulations.
Centers for Medicare and Medicaid Services
A pdf of the December 21, 2006 CMS memo of "Details for Nursing Home Culture
Change Regulatory Compliance Questions and Answers." It includes:
- Responses we have made to inquiries concerning compliance with the long-term
care health and life safety code requirements in nursing homes that are changing
their cultures and adopting new practices;
- Summarizes questions and answers from a June, 2006 CMS Pic-Tel conference
with leaders of the Green House Project (Attachment A); and
- Provides information about an upcoming series of 4 CMS culture change
satellite webcasts (Attachment B).
This is exactly the kind of dialogue and education that will help bridge the
information gap between culture change homes and regulators.
Regulatory Support for Culture Change:
How OBRA '87 Regulations Support Culture Change
by Carmen S. Bowman.
Published by Action Pact, Inc.
This workbook gives a detailed overview of regulatory support for culture
change. Author Carmen S. Bowman, a former state surveyor, speaks the language of
F-tags and discusses compliance issues in dining, resident choice, physician
orders, wireless call systems, animals, med carts, consistent staffing,
cross-training, self-directed work teams, homey environments, care planning,
waivers and variances. She provides clear explanations and recommends practices to
assure quality.
Here is an excerpt from the workbook on the Quality of Life tag:
"Tag F240: A facility must care for its residents in a manner and in
an environment that promotes maintenance or enhancement of each resident's quality
of life.
This regulation obviously supports culture change. The whole culture change
movement is about just this. Notice the regulation refers to Œeach' resident's
quality of life. Over and over, OBRA '87 re-focuses us on the individuality of each
resident. This is, of course, how it should be and isn't it great that it is
written directly into regulation? How in defines quality of life foe him or herself
is usually different that how the next person defines it, although common themes
tend to be independence, freedom and choice. Truly finding tout what quality of
life is for each person living in your care is not doubt a Herculean task. However,
discovering what quality of life entails for each person and helping them fulfill
it brings meaning and purpose to staff's work life."
Appendices include letters from CMS addressing several culture change questions,
changes in SNF payment regulations to include innovations, and the use of Civil
Monetary penalty monies. Suggested activities throughout the book will help teams
to objectively look at regulatory compliance and support of culture change in their
organization.
Household Matters Kit
(Policies & Procedures and QI sections)
Click here to order the Kit from Meadowlark Hills, or feel free to email us for more detailed information on the Kit's contents.
The Household Matters Kit was produced by Action Pact and supported by the
Commonwealth Fund, the Kansas Department on Aging and the Sunflower Foundation. In
addition to other resources for use in implementing the Household Model, the kit
includes CD-ROMs of quality improvement measurement system and policies and
procedures for the Household Model to be used as a resource on a computer or
printout. The federal regulations based manual offers policies and procedures for
organizational, administrative, human resources, leadership, development, clinical,
programmatic, environmental and support departments.
Nursing homes that have used these sections of the tool kit have shared their
experiences with us:
"We are building one of the first household-model SNFs in North
Carolina right now. We had to meet with the construction section of our state
regulator in August and I was nervous about the household kitchens. The toolkit
really helped us. It had just come out and I was able to pull up the household
kitchen P&Ps and tweak them over a weekend. They looked great and gave me the
deeper understanding I needed to have an informed conversation with regulators.
They have the thoroughness the state was looking for in terms of operations and
safety."
- Bev Cowdrick, AVP, Administrator at Huntersville Oaks of the
Carolinas Healthcare System
"We used the P&P from the toolkit as a source for revising our existing policies
so that they would reflect our households. The P&P section gave us a good place
the start. We have used the laundry, housekeeping and dietary ones the most as
those are the areas that we had strictly departmental policies before. We expect
our next survey any time and I know they will ask for our policy for residents
helping in the dining room and/or what our policy is for doing personal laundry in
the households. We now have them covered. The tool kit was a great resource as we
could "cut and paste" to individualize them for our facility without having to
start from scratch."
- Marilyn Oelfke, RN, Senior Director of Long-term Care Services at
Perham Memorial Hospital and Home, Perham, MN
