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Consumer Voice Sends Comments to CMS on Special Focus Facilities
September 15, 2016
On September 15th, Consumer Voice sent a letter to the Centers for Medicare and Medicaid Services (CMS) in support of the Special Focus Facility (SFF) program as a way to bring nursing facilities with a history of persistently poor care into compliance. The letter provided comments on the proposed SFF memo on the following issues:
- Consumer Voice agrees with with the Long-Term Care Community Coalition (LTCCC) that the number of SFF slots per state should be increased to the pre-sequestration level and that CMS should establish a plan to ultimately include all the nursing homes on the candidate list. If a nursing home’s performance is bad enough to qualify the facility for the candidate list, it should be designated a SFF.
- We encourage CMS to require that the State Long-Term Care Ombudsman have input into the selection of the SFF.
- We recommend the following agencies/entities/programs also receive written notification of the SFF selection: Adult Protective Services, guardianship programs, the QIO-QIN, the state Medicaid agency, the state nursing home administrator licensing board (a board might consider review of an administrator’s license based on the facility’s poor performance), and hospitals in the areas surrounding the SFF.
- We are concerned that although a facility may show improvement between two consecutive surveys, i.e. no deficiencies at a scope and severity of “F” or greater (or “G” or greater for LSC deficiencies) and no complaints substantiated with deficiencies at “F” or greater (or “G” or greater for LSC deficiencies), this time period is too short to indicate that sustainable improvement has been made. To better ensure that facilities have attained and maintained improvement over time prior to graduation, Consumer Voice proposes that homes that have completed two consecutive standard surveys with no deficiencies at a scope and severity of “F” or greater (or “G” or greater for LSC deficiencies) and no complaints substantiated with deficiencies at “F” or greater (or “G” or greater for LSC deficiencies), be required to remain in the SFF program.
- We recommend that at least 25% of the surveys be conducted on a weekend and/or after business hours. This would better ensure that surveyors are getting an accurate picture of conditions in the facility.
- We are pleased to see that remedies must be imposed with increasing severity, but are concerned that there is not sufficient guidance on what increasing severity means.
Read the full letter here.
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