Nursing e tags
Nursing Facility Survey & Regulations
July 31, 2023 – 02:05 am
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All nursing facilities are subject to inspection or survey by virtue of their:
- certification to participate in Medicare and Medicaid, and/or
- licensure by the state in which they operate.
State licensure standards, generally, have followed Federal certification standards, and state personnel perform the vast majority of surveys - simultaneously assessing compliance with both licensure and certification requirements. The Federal government also provides training for state surveyors and periodically conducts inspections with federal surveyors as a check on the performance of state surveyors. These are called FOSS surveys (Federal Oversight and Support Surveys). Compliance with the survey process and requirements established by the Centers for Medicare and Medicaid Services (CMS) and published in the State Operations Manual (SOM) is the primary regulatory focus for nursing facilities and consultant pharmacists.
The information contained in this section applies to both the skilled nursing facility (SNF) and the nursing facility (NF) categories of facilities. (See Glossary located in Appendix A of SOM for definitions of these categories.) Not only will these standards be reviewed during the facility’s annual survey, but they may also be reviewed during any inspection resulting from a complaint against the facility. Furthermore, any deficiency cited against the facility will result in regulatory and/or monetary penalties to the facility, will become a part of the public record about the facility, and may reflect poorly on the providers and facility.
The SOM has multiple components and sections. Appendices P, PP, and R of the SOM are the three appendices related to the nursing home setting.
Each Appendix includes the:
- Regulations, including the regulatory citation from the Codified Federal Regulations (CFR),
- Tag numbers (the alpha-numeric indexing system used to denote specific sections in each SOM Appendix), and
- Interpretive Guidelines, also known as “Guidance to Surveyors.”
For some of the recently revised Tags, CMS includes additional guidance to surveyors related to deficiencies for that particular Tag, namely deficiency categorization and severity guidance.
For example, SOM Appendix PP contains CFR Section 483.60 dealing with the standards for providing pharmacy services to a long-term care nursing facility. This section of the regulations is divided into three F-Tags: F-425, F-428, and F-431. The “F” preceding the term “Tag” indicates that the section pertains to long-term care facilities and can be found in Appendix PP. Each SOM Appendix has its own Tag designation (e.g., W-Tags for ICFs, G-Tags for Home Health Agencies, etc.). When a survey identifies a deficient practice and non-compliance with the regulations and guidelines, the surveyor must name the specific Tag under which the deficient practice falls. This is how the citation is officially classified and documented.
It is important for the consultant pharmacist to understand all regulations and interpretive guidelines applied to these facilities, especially those that relate specifically to pharmacy.
The major pharmacy-related F-Tags include:
- F-Tag 309: Quality of Care
- F-Tag 329: Unnecessary Drugs
- F-Tag 332-333: Medication Errors
- F-Tag 425: Pharmacy Services
- F-Tag 428: Medication Regimen Review
- F-Tag 431: Storage, Labeling, and Controlled Medications
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The College of Nursing and Health Professions (CNHP), is a college of Drexel University. The college offers six undergraduate degree programs and seven graduate degree programs.
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