The Steep Price of Poor Risk Management in Skilled Nursing Facilities: A Closer

Poor risk management can cost skilled nursing facilities in many ways. Here are seven of the most common:

Legal and Financial Consequences:
SNFs face lawsuits and penalties for failing to manage risks. Poor risk management practices can expose SNFs to significant legal and financial consequences, including lawsuits, fines, and penalties. These legal and financial costs can be significant, and in some cases, may even threaten the financial viability of the SNF. SNFs must ensure that they have effective risk management policies and procedures in place to prevent these costly consequences.

Reputation Damage:
Poor risk management can damage the reputation of a SNF, leading to decreased enrollment and reduced revenue. SNFs that are perceived as having inadequate risk management practices may suffer from reduced demand for their services. This can lead to decreased enrollment and reduced revenue, ultimately impacting the financial viability of the SNF. To prevent reputation damage, SNFs must prioritize effective risk management and demonstrate their commitment to resident safety and wellbeing.

Increased Healthcare Costs:
Weak risk control measures can lead to outbreaks and infections. When SNFs fail to manage the risk of infection, they can experience outbreaks that require significant healthcare resources to manage. This can include increased staffing, increased use of personal protective equipment, and increased use of medications. These increased healthcare costs can impact the financial viability of the SNF and may also lead to reduced quality of care for residents.

Loss of funding:
Substandard risk handling can lead to loss of funding from government agencies and other sources. SNFs that fail to meet regulatory requirements for risk management may lose funding from government agencies, such as Medicare and Medicaid. They may also lose funding from other sources, such as private insurers or charitable organizations. Loss of funding can be a significant financial blow to the SNF and may threaten its ability to continue providing care to residents.

Staff Burnout:
Deficient risk assessment can lead to increased workload and stress. When SNFs fail to effectively manage risks, staff may be required to take on additional responsibilities or work in high-stress environments. This can lead to burnout, job dissatisfaction, and increased turnover rates. To prevent staff burnout, SNFs must prioritize effective risk management and ensure that staff have the resources and support they need to provide high-quality care.

Resident Harm:
Insufficient risk mitigation can lead to harm or injury to residents, which can lead to decreased quality of life, physical and emotional harm, and in some cases, death. SNFs have a responsibility to protect their residents from harm, and poor risk management can lead to serious harm or injury. This can impact the quality of life of the resident, as well as their physical and emotional wellbeing. In extreme cases, poor risk management can even lead to death.

Reduced Confidence in the Healthcare System:
Inadequate risk management can reduce public confidence in the healthcare system, leading to decreased trust with SNF operators. When SNFs fail to effectively manage risks, they can erode public trust in the healthcare system. This can lead to reduced demand for healthcare services, as well as increased scrutiny from regulatory bodies and the public. To maintain public confidence in the healthcare system, SNFs must prioritize effective risk management and demonstrate their commitment to resident safety and wellbeing.

We understand the importance of managing risks in our industry. That’s why we created Risk Suite. A suite of software applications and reports are integrated within your existing systems. No double-entry or accessing multiple data sources is required to obtain optimal risk reduction results. Risk Suite simplifies your risk management program and may even reduce your insurance costs.

Ellsworth Harris is Channel Sales Director at SNF Metrics

The Financial Toll of Non-compliance in SNFs: Understanding the Top Risk Expenses

The nursing home industry is highly regulated, with federal and state regulations governing every aspect of care, from staffing levels to resident safety.

Failure to comply with these regulations can result in fines, penalties, increased insurance premiums and unforeseen expenses that can have a significant impact on a nursing home’s financial stability and reputation.

It is crucial for operators to be aware of the potential consequences of noncompliance and take proactive steps to ensure that your facility is meeting all regulatory requirements. In this explanation, we will delve into the top 7 SNF fines, penalties, and unforeseen risk expenses that nursing homes may face, and provide a brief overview of each.

CMS Fines:
The Centers for Medicare and Medicaid Services (CMS) can impose fines on nursing homes for violating federal regulations related to resident care and safety. These fines can be substantial and can negatively impact a nursing home’s reputation and financial stability.

State Fines:
States can also impose fines on nursing homes for violating state regulations, such as those related to staffing levels and quality of care. These fines can vary in amount but can still be significant and can also affect a nursing home’s reputation and financial stability.

Class Action Lawsuits:
Nursing homes can face lawsuits and fines for widespread violations, such as neglect and abuse. Class action lawsuits can be particularly damaging, as they often result in large payouts and negative publicity.

Large Settlements:
Nursing homes can be held liable for neglect and abuse, medical malpractice, and wrongful death. These types of cases can result in large settlements and can severely impact a nursing home’s financial stability.

Civil Penalties:
Nursing homes can be penalized for violating federal and state regulations, including for failing to properly report incidents of abuse and neglect. These penalties can include fines and negative publicity.

Loss Of Funding:
Nursing homes can lose funding for violating regulations, including those related to resident care and safety. This can have a significant impact on a nursing home’s ability to operate and provide quality care.

Insurance Premium Increases:
Nursing homes that have repeated violations and lawsuits can see their insurance premiums increase, leading to reduced profitability. This can also make it more difficult for nursing homes to obtain insurance coverage in the future.

We understand the importance of managing risks in our industry. That’s why we created Risk Suite. A suite of software applications and reports are integrated within your existing systems. No double-entry or accessing multiple data sources is required to obtain optimal risk reduction results. Risk Suite simplifies your risk management program and may even reduce your insurance costs.

Ellsworth Harris is Channel Sales Director at SNF Metrics

Managing Legal Risks in Skilled Nursing Facilities: Essential Lawsuit Categories to Watch

As nursing home populations continue to grow, so do the number of lawsuits filed against skilled nursing facilities (SNFs). From neglect and abuse to medication errors and falls, SNFs can face legal action for a range of reasons.

Being aware of the top lawsuit categories can help SNFs take proactive measures to prevent such incidents and minimize potential legal liabilities. In this blog, we will discuss the top seven lawsuit categories that SNFs should be familiar with, including neglect and abuse, improper care, improper restraints, falls and accidents, bed sores and infections, wrongful death, and discrimination. By understanding these categories, SNFs can better protect their residents and their own legal interests.

Neglect and Abuse:
Any behavior neglecting or abusing residents, including physical, emotional, and sexual abuse. SNFs have a legal duty to provide a safe and secure environment for their residents. When they fail to do so, they can be held liable for any harm caused to the resident.

Improper Care:
Failing to provide proper care, including inadequate staffing, medication errors, and neglect of hygiene. SNFs must provide appropriate care to their residents and ensure that their medical needs are met. When SNFs fail to provide proper care, it can result in harm to the resident.

Improper Restraints:
This classification encompasses using improper restraints leading to injury or harm. When restraints are used improperly, they can lead to injury, harm, or even death.

Falls and Accidents:
This group involves falls and accidents resulting from inadequate staffing, failure to supervise residents, and failure to provide adequate safety measures. SNFs must provide a safe environment for their residents and take measures to prevent falls and accidents.

Bed Sores and Infections:
This type of claim includes bed sores and infections resulting from improper care, including inadequate turning, and repositioning and failure to prevent pressure ulcers. SNFs have a duty to prevent bed sores and infections from occurring by ensuring that their residents receive appropriate care and treatment.

Wrongful Death:
This classification covers death due to neglect, abuse, or medical malpractice. SNFs can be held liable for wrongful death if they fail to provide proper care, including medical treatment and medication, leading to a resident’s death.

This category involves discrimination based on race, gender, religion, or other protected characteristics. SNFs must ensure that their residents are treated fairly and without discrimination. When discrimination occurs, it can result in legal action being taken against the SNF.

We understand the importance of managing risks in our industry. That’s why we created Risk Suite. A suite of software applications and reports are integrated within your existing systems. No double-entry or accessing multiple data sources is required to obtain optimal risk reduction results. Risk Suite simplifies your risk management program and may even reduce your insurance costs.

Ellsworth Harris is Channel Sales Director at SNF Metrics

5 Best Practices of Successful SNF Operators Industry Trends Leading Into 2023

One principle is certain in skilled nursing and that, unfortunately, is change.  Today, caring for our seniors couldn’t be more intense.  Covid-19 devastated both our seniors as well as their caregivers.  Policy-makers imposed regulatory restrictions that the industry suggests have limited impact on care quality:  Nearly 850 pages of CMS-imposed guidelines went into effect late last year.  The industry is seeing an unprecedented number of ownership transfers and facilities forced to close their doors due to economic hardship.  Top SNF organizations are in an ongoing clinical staffing crisis with nearly 30% of SNFs reporting critical staffing challenges.  Additionally, hospitals continue to report high levels of extended occupancy as many SNFs report having low staff volumes to take their recovering patients.  


In light of ongoing and new challenges facing SNF organizations, what are today’s top habits that contribute to strong, successful SNF operations? 


Habit #1- Staff Appreciation!  We have never seen so many heroes at all levels of an SNF operation going above and beyond for resident care, and resident safety and just working hard to make a strong community committed to doing the right thing.  Operators that truly embrace their staff in all departments and roles continuously have better outcomes.  Make time to take time to enhance your culture of caring and respect.  They have led us through one of the most challenging times in senior care and continue on today, albeit at lower staffing levels. Leadership that constantly celebrates staff creates an environment others desire.  The employee that brings home a paycheck is an employee.  An employee that brings home a paycheck, a photo of the CEO serving them lunch to share with friends and family, or a manager hosting a “Lunch and Learn,” asking staff how they can do better for them—builds a partnership. Build partnerships.   

Which organization would you rather work for? The employee that feels appreciated post about it, shares their stories with friends and families, and tells colleagues working at other facilities about it. Your ability to hire experienced team members has just been greatly elevated.  You have now achieved positive operational results.  Step it up in 2023!  

Habit #2- Healthy Accounting: Nothing else matters if your Accounts Receivable personnel and systems are not aligned and maximizing your collections.  Top operators “live and breathe” AR as a way to pay staff well, improve care and perpetuate healthy SNF operations.  In recent interviews, top operators point to live and interactive SNF-based financial software systems such as SNF Metrics’ that integrate multiple software systems together for fast, real-time insights.  The SNF Metrics App quickly shares billing concerns with top managers, reduces the incidence of untracked residents, takes control of managed care reimbursements, manages co-pays in a timely manner, reduces bad debt expenses, and maximizes PDPM payments.  Take time in 2023 to review a new SNF-based financial system.    


Habit #3- Census and Referrals: SNF Operators who are passionate about resident census find improved successes.  Recently, our industry saw a trend similar to what we traditionally have only seen from our Assisted Living friends-structured divisions of sales and marketing professionals dedicated to community outreach and education.  Today, SNFs have many more opportunities for health system partnerships, Medicare Advantage participation as well as our standard hospital admission relationships. Successful operators are adding census management tools and building teams of professionals to help them share their “top-notch” clinical care, and safe and comfortable senior living experiences.  Here in Baltimore, MD, one SNF Operator is even marketing themselves with billboards as the official nursing home of the Baltimore Ravens!      

Habit #4-  Spot Your Trends Early: Lessons from other industries point to the need to collect, analyze and quickly respond to what the data is telling us.  In an SNF, trends can cover both our management operations as well as resident clinical care. SNF operators download data into multiple data sources every second.  Successful operators employ tools to unlock that data—and then build trust in that data to make informed decisions.  A word of caution:  An operator that employs data-driven management must drive staff at all levels to embrace this approach.  Just having data analytics tools has no impact if it is not utilized by all levels of an SNF operation-starting with ownership.  SNF data holds the answers to great care, census development, and much more.  Drive it home!   


Habit #5- Risk Management: Recent developments have mandated that successful SNF operators take risk management head-on.  SNF operators face internal challenges, resident/family/legal challenges as well as more pressure from CMS–most recently new risk regulations related to abuse and neglect.  Today, top operators are building entire risk management teams to control risks, reduce costs, and lower insurance premiums.  Risk management software applications and risk reports from SNF Metrics direct SNF operators to where their risk exposures are occurring and mitigate those risks quickly.  Additionally, the top habits of top operators are that they are overseeing these new risk operations personally.  The software can make this oversight simple, and accurate and provides confidence in the entire SNF operation-from legal, investors, C-suite, staff, and of course residents and families.     


SNF Metrics provides savvy SNF operators with Apps and Analytics to drive the most critical facets of their operations in 2023 and beyond.  Apps and Analytics that oversee clinical, census, staffing, AR, managed care contracts, pharmacy auditing tools, and risk management with more in development.  Simple to use, simple to integrate at simple prices.  Leaders that embrace our innovative tools perform better than those that do not, and we have the proof. Call today to learn how. 

Strategies to Comply with New Risk Management Requirement

On 24 October 2022, the Centers for Medicare & Medicaid Services (CMS) issued an 847-page document updating its 2016 regulatory guidelines for nursing home surveyors. The document represents part of the Biden-Harris Administration’s initiative to promote the safety and quality of nursing home care across the country.

These updates empower surveyors to collect additional data and conduct more interviews, causing concern among industry analysts. The guidelines suggest that the CMS wishes to address issues such as crime, abuse, neglect, and elopement, leading to more citations and fines.

The guidelines also require better data analysis from nursing homes, stating that a nursing home must “establish and implement written policies and procedures for feedback, data collections systems, and monitoring, including adverse event monitoring.” They also require the establishment of a system of risk reporting as well as developing risk mitigation strategies.

Through its Risk Suite, SNF Metrics has been helping nursing homes manage all risks with its proprietary App and live insights. Risk Suite will help you input all risks, manage them, and ensure compliance and reporting. It will give you confidence that risks are being monitored and appropriately handled. Share your risks and devise risk mitigation strategies both inside and outside your organization as well as with families, lawyers and underwriters.

Contact us for a Risk Suite brochure and schedule a short product demonstration to see if SNF Metrics’ Risk Suite is right for you.

Risk Suite also provides optional Apps and reports to manage grievances as well as workers’ comp claims.

Optimize Your Nursing Home Operation

SNF Metrics was thrilled to be a supporter of the Zimmet Reimbursement Conference this year. 1,300 SNF operators, clinicians, owners, administrators and partners came together to peel away the layers and layers of reimbursement misunderstandings and refine our skills, share stories and get a clear, accurate update on what’s to come.

As I sat in the back of the presentation hall, probably 20 rows deep, I had an interesting view of what attendees were doing while participating in the Conference.

From my post, I can see the screens of at least 30 folks’ laptops. I can’t see the details-and nor do I want to–but I can see what they are all doing. They are all accessing their analytics platforms and checking their operations. Two are even checking the cameras installed inside and outside their facilities. I see busy spreadsheets EMR reports and charts which are then triggering massive emails and texts, probably back to front line staff.

Sitting there for 2 hours, many are still going. There is a better, faster more efficient way. It’s unanimous that the data we capture and review is massive and growing. The data is important–but can be time-consuming to turn it into actionable insights. My time here today proved that.

SNF Metrics took an operator’s frustrations with this process and made it better. Live reports and proprietary applications take your data from multiple data sources and present it exactly the way you want it when you want it.

One example comes to us from a Regional Nurse Consultant for a nursing home group in North Carolina. In the morning, she opens an email generated by the SNF Metrics platform. She has customized her daily reports to focus on falls and wounds over her portfolio of homes over the last 24 hours. She then expands her report to review the care plans–were they updated? She tells us she captures missed care plan updates every week.

Another example comes to us from a group in Missouri where they agonize on predicting their QM scores and what they can do today to get the coveted 5 star rating. They tell us they spend hours pouring over data, reviewing EMR records, and even then they don’t have confidence in their results and action plan. Now they receive a weekly email that shares actionable QM data that identifies concerns and areas of QM score improvement. Actions are quickly implemented. They share with us that, next week or next month, they can quickly see the impacts of their actions. They use this to praise their teams for their hard work. Examples like this come to use every day, from risk reduction, staffing, census, AR, as well as pharmacy and managed care contract management.

Give your leadership time back to be mentors, educators and share their experience with your teams. Check out SNF Metrics to optimize your nursing home operation.

Elsworth Harris is Sales Director at SNF Metrics.


Leading LTC Data and Service Organizations Partner to Deliver


Five organizations that serve Long Term Care facilities have teamed up to create Tracking-19, a free resource that helps nursing homes to manage the exponential increase in the number of COVID-19 related requirements.  SNF Metrics, SHOPP, PRIME SOURCE, Zimmet Healthcare, and People Powered Nursing created Tracking-19 and the associated app that fills a desperate need for reliable and efficient infection tracking and reporting for both residents and employees. The app also helps nursing homes meet continually changing reporting expectations by government bodies like the CDC, and State and County Health Officials. The benefits beyond COVID-19 will be the ability to track signs and symptoms for residents to get ahead of infection outbreaks. 


“Long term care facilities have their hands full during the pandemic caring for residents and ensuring their employees are healthy and safe.” said Ken Berger, COO of SNF Metrics. “Add to this, the new reporting demands and employee testing requirements. This puts an impossible strain on LTC organizations already struggling to cope with the toll this virus has taken on the industry.”


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The complimentary app offered on takes the guesswork out of employee and resident COVID-19 testing, tracking and reporting. Facilities can easily use the app to input line listing and employee testing data from any department or any facility. The app, updated daily, will always have the latest reporting requests and formatting so facilities can devote more time to resident care and employee safety and not struggle with version control, time-consuming duplication, manual tracking and careless errors as a result of unimaginable workloads. 


“This gives all parties the confidence to win in this pandemic,” said Michael Greenfield, CEO of PRIME SOURCE.  “Residents are getting the best care, employees know they are working in a safe environment with reduced risk of infection to themselves or the residents they care for, our government partners are getting the data they need, residents’ families feel relieved their loved ones are in good hands and the facility operators have the right data to know they are running their organizations in the best way possible under unimaginable circumstances.”

Country-wide, long term care facilities face steep financial penalties, and could face permanent closure of their facilities if they are not able to comply with the changing government reporting demands. 


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Tracking-19 is available now and is free to facility operators in the USA. Visit Tracking-19 is the result of expert collaboration between five industry-leading private companies: The Society for Healthcare Organization Procurement Professionals; People Powered Nursing; Prime Source; SNF Metrics; and Zimmet Healthcare Services Group

Tracking LTC Resident and Employee Data In The COVID-19 World

It seems we have an acronym for everything- CMS, DPH, MDS, IDT to name a few.   It’s a surprise to no one that the world of LTC is a big bowl of alphabet soup. And now the dreaded COVID-19 joins the list of names and acronyms that we have to address.

Its been a rough and tragic time for our industry with much illness, death, negative media, and severe lack of supplies and staffing. Under this level of attention and scrutiny, our facilities are faced with an ever-increasing list of metrics to track and manage.

I expect that in the wake of COVID-19 , tracking our numbers and using them to take calculated action will be essential to our survival as an industry.

But, what data do we need to know and track in this new COVID world?

Line Listing

If you’ve never heard of line listing before COVID, you sure are intimate with the concept now.

The CDC defines it as “one type of epidemiologic database and is organized like a spreadsheet with rows and columns. Typically, each row is called a record or observation and represents one person or cause of disease.”  I define it as my COVID Survival Document.   It is the basis of tracking the disease in your facility and a template for completing the many documents that have to be submitted to the State, County, and CDC on sometimes a daily basis.  The data in this spreadsheet needs to be accurate and consistent and this can be a tedious task.

According to a CMS Memorandum of May 19, 2020 COVID  “all nursing home staff (including volunteers and vendors who are in the facility on a weekly basis) to receive a single baseline COVID-19 test, with re-testing of all staff continuing every week.”  While there is an ability for state or local leaders to adjust the requirements- there will be requirements.   This tracking will become a very difficult job for the already overtaxed HR departments.


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Temperatures and Oxygen Saturation

Anyone who has attempted to buy a thermometer lately knows they are in high demand.  In fact, let me know where you find one!

As providers, we are scrambling to find a data set that gives us an early warning. This early warning is the key to reducing the risk of infection. We are looking for data insights that we can trust and will inform our actions.   Many facilities are now routinely tracking temperatures of residents and staff and carefully looking at resident oxygen saturations.  Make sure you create the policies and the processes to track this information in a way that is easy to access, both for data input and data analysis.

Staffing/ PPE

Having worked in LTC for most of my professional career, I cannot recall a time where tracking of Staffing and Personal Protection Equipment has been more critical.  We are carefully tracking these precious supplies and calculating utilization and need on a daily if not hourly basis.  Looking forward, I think it will be essential to have a clear “story” of what supplies were available and what we did regarding shortage- both for staff and PPE.

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Looking into the not so distant future, I anticipate we will see an increase in lawsuits and serious DPH findings with expensive fines and penalties.  It’s critical to also track all the things WE HAVE DONE RIGHT.  We should keep a careful dateline of all the things that were done by the facility and how we responded at every step of the way.


The time is NOW to start considering how you are tracking these new data points and concerns.  Work with forward-thinking vendors, like SNF Metrics to ensure you stay ahead of the curve.  We are operating in a new world where we are expected to be hypervigilant in tracking and trending in order to prevent the spread of illness in our buildings.

Meeting a CIA Challenge with Innovation- The Marquis and SNF Metrics Story

There’s a great article written by Michael Smith, Division President of Marquis Health Services published in the July 24 edition of McKnight’s online. Michael discusses his company’s journey through a Corporate Integrity Agreement (CIA). I had the privilege and pleasure to work with his team on their compliance journey and witness their commitment and what they were able to achieve. When I begin my relationship with a client, I start with two messages: Tackle what keeps you up at night and let’s make lemonade out of lemons. How did Marquis do these do things effectively?

Tackle what keeps you up at night

The team at Marquis “inherited “this CIA. When they took over the management the facility, a preexisting CIA was in place, and with which they were required to comply. In addition to the headache that comes with taking over a new building, the team was also dealing with CIA requirements and visits from Federal Monitors. I would start every site visit by asking the team the same questions: What’s keeping you up at night? We learned very quickly that A LOT of things kept them up at night, so much so that it was difficult to assess real strengths and weakness.

As a team, we decided that the best first step would be to sort through the existing data, specifically clinical, to find the areas of greatest liability that required immediate attention. As it turns out, this was easier said than done.

During these early transitional stages, it appeared that the data we received differed depending on the nurse on duty, DON at the helm and many other factors. The variability was getting in the way of our ability to quickly pinpoint our risks, trends, and successes. One of our first objectives became to ensure the data was the same month over month- not at the discretion of the clinician. For added incentive, the OIG and federal monitors were challenging the team to create systems for consistent data analytics. These systems would enable the organization to self-identify issues, conduct root cause analyses, and put the appropriate corrective measures in place. To make this task easier and to change the culture of the facility, the team developed an internal tool to organize the data and to perform critical data analytics. Finally, with the systems in place and to my delight (and to the delight of the OIG) when asked “what’s keeping you up at night?”- the team was able to quickly and efficiently provide the data and see the path to improvement.

Making Lemonade out of Lemons

While our primary goal in this CIA was to meet the government’s standards, Marquis was challenged to take it a step further. Instead of just implementing the CIA to check the box, what can we do to change the way we do things- and spread those changes? Through the innovations of this team, Marquis was able to implement and further develop data analytics for the entire company. In speaking to Smith, they have seen an overall reduction in the number of survey findings and complaint surveys, since they have implemented this data analytics within their entire operation.

But why stop there? Marquis realized that if this system helped them, then it might also be a useful tool for other LTC organizations. So the Marquis team developed a sophisticated data analytics platform and created the SNF Metrics company. The platform is always evolving based on industry changes and provider needs.

The SNF Metrics solution is a data analytics platform that centralizes data from all of your company systems (Clinical/EHR, Financial, Payroll, Billing, etc.) into a single, easy to navigate dashboard. The platform also includes several applications that were built to automate and systematize manual processes. This way, those manual processes can also be a source of data. The integrated data platform from SNF Metrics takes all of that data and applies critical analyses so operators can see patterns in their data, can quickly identify issues and opportunities, and finally feel focused in a chaotic environment.

To learn more about the SNF Metrics Platform and how it might help you and your organization to find focus in the chaos, visit the website at or call (732) 836-8300.

Compliance Program Series: Response to Problem and Corrective Actions

This post is one in a multi-part series on Compliance Program Success Factors. Start at the beginning: Compliance and Policy Procedures with OIG

It’s been a long journey- so far, we have covered the first 6 elements of creating an effective compliance program based on the recommendations of the OIG. (Policy & Procedures RequirementsDeveloping Policies & ProceduresTraining & EducationEnforcement & DisciplineExclusion Checks and  Monitoring and Internal Audit Systems).

We have come to the final element- response to problems and corrective actions.  We have developed systems to self-identify our problems. However, self-identifying the issues is only the first step. Next, we need to define how we will correct them and develop effective systems to ensure they don’t happen again.

In long term care we are very fond of acronyms-OIG, CMS, ZPIC, QAPI and the list continues.  Today I would like to throw PIP into the mix.  What is a PIP? It’s a Performance Improvement Plan- the system that measures success and quantifies our improvements plan.  A PIP is an essential part of the quality improvement plan but it’s a process that is applicable for any perceived issue that a facility might face.

A Performance Improvement Plan (PIP) is a concentrated effort to address a specific problem in the facility.  This can address one area of the facility or it can be facility-wide and it isn’t limited to clinical or quality of care issues.  A PIP can be initiated based on the recommendations of the compliance committee.  The process involves gathering information systematically to clarify issues or problems and intervening for improvements. The facility conducts PIPs to examine and improve care or services in areas that the facility identifies as needing attention. Areas that need attention will vary depending on the type of facility and the unique scope of services they provide.

CMS has some great resources and  guidance on their website. The first place I advise clients to start is by creating a Storyboard for the problem you are looking to solve.  What is a Storyboard? It’s a tool that staff can use to simply communicate the story of the proposed PIP.  It helps staff drill down to the most essential pieces of information and create clarity for what you are trying to accomplish.

CMS guide to QAPI recommends the following key content to Include in your Storyboard:

  1. Problem. One sentence on the issue or opportunity being addressed by this PIP.
  2. Aim. One sentence on what this PIP aims to achieve.
  3. Intervention(s). Briefly describe what change was introduced to address the problem or opportunity. If there was more than one change, use bullet points to list the multiple interventions.
  4. Measures/Indicators. List what measure(s) or indicator(s) are being used to monitor whether the change is effective.
  5. One to two sentences on the results. Consider including a graph with notes that gives a picture of the impact of the changes over time, or stories that describe the success.
  6. Lessons Learned. Document 1-2 key lessons that were learned through the PIP.
  7. Next Steps. Performance improvement is a continuous process. In one to two sentences, describe the next steps (e.g., to further refine the intervention; to introduce the change in other parts of the nursing home; to take steps to standardize the change).

What do I believe makes for a successful PIP?

  1. IDT Involvement: Get perspective from the entire team. For example, the maintenance manager sees things a floor nurse might not.
  2. A Clear Definition of the Problem: The team needs to be clear what the problem is and how will we measure the solution. I often encourage the team to drill down smaller and smaller- make your problem very specific so you can feel success and work through the process.  Afterall, Rome wasn’t built in a day.
  3. Support From Administration: Support needs to come from the top.  Administration is interested in results and bottom line.  There must be buy-in to all PROCESSES and SYSTEMS.
  4. It’s A Real Solution, Not A Quick Fix: The main point to a PIP is not to be a band aid- or short-term fix but rather to dig deep and create systems to correct and monitor.

With this review of Element 7, we have outlined the OIG recommendations for implementing a Compliance Program in a long-term care facility, specifically around responding to problems and taking corrective action.  The next step in this series is examining what CMS is looking for in their mandated compliance program and how it reflects the OIG recommendations.  Nothing is simple, right?


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