The much-anticipated release of the revised F325 and F371 tags is scheduled for this July. The specific regulations won't change, but the Interpretive Guidelines, Surveyor Investigative Protocols, and guidance on scope and severity have received major revisions.

 

How can you and your staff prepare for the changes?

 

F325: For this particular tag, start with your Quality Measure/Indicator Report to review all high-risk residents. As you review these individuals, you can be more prepared if you ask the following questions. Do all of your nutritional assessments include calculated needs for calories, protein and fluid? Are these needs individualized based on current medical status and updated with changes in residents' condition? You need to remember when a resident returns from the hospital or receives a new diagnosis, nutrient calculations need to be reviewed, modified and changes documented as needed.

 

Another area that should be addressed is abnormal laboratory results. Who is notified of abnormal laboratory tests and have they been reviewed with the proper individuals? In addition, have interventions been implemented if indicated? You need to pay close attention to fluid-related indicators and review how fluids are provided throughout the day. In doing so, don't forget the residents on thickened liquids. Are thickened liquids available at bedside, in activities and in therapy as needed? Are your medications being dispensed with the proper liquid consistencies? Now that the warmer months are here, it is a good idea to provide residents with Popsicles or sugar-free lemonade in a common area, but make sure to make the appropriate accommodations for all of your residents, especially those on an altered diet.

 

You will also need to look at the care plans. Are they current with ongoing evaluation of goals and the effect of interventions documented? Compare written approaches to what actually happens in the dining room. Be sure to get resident and family input regarding interventions, food/fluid preferences and document their involvement. Have risks and benefits been discussed and documented for any refusals of MD orders?

 

In getting ready for the new survey process you need to prepare yourself and all staff for more in-depth interviews by the surveyors. For instance, how is the doctor or nurse practitioner being notified of changes in diet or fluid intake? Overall, you may need to re-evaluate the chain of communication to ensure that all staff on all shifts are on the same page when it comes to diet changes and the resident.

 

F371: This tag is already on the top-ten lists of deficiencies; the revised Investigative Protocols will guide surveyors to more areas for evaluation of compliance. There is an increased expectation that staff will be more knowledgeable in proper sanitation, proper food preparation, proper storage and handling of food. Review the proper use of gloves with your staff. You may need to remind them that it is not okay to answer the phone or open the refrigerator door while wearing gloves and then continue to prep or serve food without washing hands and changing gloves. Also reiterate that 25% of food borne illness can be prevented with proper hand washing.

 

Check the refrigerators in pantries and kitchenettes for proper labeling and dating. Is a dairy-based med pass supplement used? If so, is it temperature controlled while on the med cart?

 

Review your water passes. Is there any human contact with drinking surfaces of the cups/mugs and is ice dispensed correctly?

 

What's your policy on staff illness - when are they allowed to work?

 

Both F371 and F325 have lists of potential tags for additional investigation. If the surveyors identify concerns related to outcome, process and/or structure requirements, the proposed draft states that they should investigate additional tags. For example, if surveyors identify infection issues in the nutrition department then they may review F322 - Nasogastric tubes - to determine if staff is using universal precautions and clean technique when administering enteral feedings, using hang-time recommendations by the manufacturer to prevent microbial growth and implementing procedures to ensure cleanliness of supplies.

 

For an in-depth review of these changes and how you can be ready for survey, plan on attending an upcoming class on F325/F371 at one of Pathway's Fireside Education Centers.