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01/2006 |
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Donna J. Senft Appeared in Geriatric Nursing Section 941 of the Benefits Improvement and Protection Act of 2000 created a requirement for Medicare- and Medicaid-certified nursing facilities to “post daily for each shift the current number of licensed and unlicensed nursing staff directly responsible for resident care in the facility.” This legislation further required the information to be displayed in a uniform manner and in a clearly visible place, with data to be available to the public on request. Despite the passage of this bill in 2000, it was not until January 1, 2003, that nursing facilities were required to begin adhering to this legislative mandate, and final regulations were only recently published on October 28, 2005. The final regulatory requirements are effective December 27, 2005. The most noted change from previous Centers for Medicare and Medicaid Services guidance regarding posting nurse staffing data is the shift from reporting data in terms of full-time equivalents (FTEs) to posting the total number of hours for each staffing category. CMS determined that in addition to decreasing the time required to prepare the staffing report (i.e., requiring on average only 5 minutes per day under the new guidance), displaying FTEs would not provide sufficient information regarding staffing at a given point in time. For example, the same data (e.g., 1.0 FTE) would be reported if 2 RNs work the beginning 4 hours of an 8-hour shift or 1 registered nurse (RN) worked the full 8-hour shift. Therefore, to enhance the usefulness of the report, a certified nursing facility must now report both total hours worked and the actual time providing direct resident care. Before completing the staffing data report, nursing facilities will need to differentiate which staff members are and are not providing direct care to residents because only hours of nursing staff assigned and responsible for direct resident care are to be reported. “Directly responsible” is defined to include, performing nursing assessments at admission or change in status, administering medications and tube feedings, assisting residents with activities of daily living, and supervising certified nursing assistant (CNA) care. Direct care staff that perform administrative functions, such as the completing and submitting minimum data sets data or conducting interdisciplinary team meetings, are instructed not to include the hours spent performing these administrative functions when calculating direct nursing care hours to be reported. Facilities are provided latitude under the final regulations to expand the posted report to list administrative nursing staffing as well; this is not required, however. In addition to nursing staffing data, nursing facilities must report the resident census during each nursing shift. Simultaneous posting of census information is required by CMS to make the staffing data more meaningful and useful to the public, that is, to provide a basis to understand and compare relative numbers of nursing staff. What to Report When to Report Where to Post the Report Format to Use Other Requirements Unless state law requires a longer period of record retention, staffing data reports are to be retained for a minimum period of 18 months. CMS established this period to have the record retention coincide with the annual survey process. |
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Ober, Kaler, Grimes & Shriver Maryland
Washington, D.C. Virginia |
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