Centers for Medicare and Medicaid Services
Long Term Care
Requirements for Participation for Phase 2, effective November 28, 2017:
A Survey and Certification memo outlining changes to the Interpretive Guidance of the revised Requirements for Participation:
An update to regulations and a practice tip for practitioners to prepare for their implementation:
Centers for Medicare and Medicaid Services, The Joint Commission and the Healthcare Facilities Accreditation Program streamlined regulations and interpretive guidelines and standards and elements of performance in 2015 and 2016 to guide quality patient care and assist providers of services to achieve best practices.
These updates may seem to change the nutrition care services that registered dietitian nutritionists and nutrition and dietetics technician, registered provide. This is not the case.
Rather, RDNs and NDTRs are expected to meet the regulations and interpretive guidelines per CMS, and the standards and elements of performance per TJC and HFAP depending on which accreditation organization is contracted with an organization/hospital facility. TJC and HFAP are now aligned with the CMS regulations.
Note that TJC always holds to policy and procedures and will question the hospital department via the tracer methodology. If nutrition screening is part of the clinical care workflow process in the organization/facility, then identify it as a best practice.
It is suggested to utilize information needed to make a decision on nutrition assessment and nutrition intervention/plan of care from data points that trigger a consultation within the nursing assessment or electronic health care record system.
Take the opportunity to retool nutrition and dietetics services labor allocation and job functions/specifications to shift nutrition care process to include nutrition screening and control and lead the nutrition business of patient services.
Centers for Medicare and Medicaid Services
Medicare and Medicaid Programs; Revisions to Requirements for Discharge Planning for Hospitals, and Home Health Agencies
CMS published a proposed rule in November 2015 (final action to be determined by November 2018) to revise the discharge planning requirement for hospitals (general acute, long-term care hospitals, inpatient rehabilitation facilities, and psychiatric hospitals), critical access hospitals, and home health agencies. The provisions address discharge planning policies and procedures, applicable patient types, timing, people involved, criteria for evaluation of discharge needs, discharge instructions, post-discharge follow-up, transfers, and other hospital requirements. Learn more about the rule and its provisions.
In the proposed rule, CMS expressed concern with the variation in the discharge planning process and is looking to require that all patients receive a discharge plan. Other requirements deal with timing (ie: a copy of the discharge plan and summary be sent to the practitioners responsible for the patient’s follow-up care within 48 hours) and another requirement is for the hospital to establish a post-discharge follow-up process to check on patients who return home.
Hospital CoP updates and revisions are continuously released by CMS, and discharge planning, CoP 482.43 is highlighted to assist with limiting readmissions. Read a review of the discharge planning services requirements from the National Health Policy Forum.
Medicare and Medicaid Programs; Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction; Part II
In this final rule, The CMS Hospital and Critical Access Hospital Conditions now allow a hospital and its medical staff the option to include RDNs within the category of “non-physician practitioners” eligible for credentialing for appointment to the medical staff or be granted ordering privileges, without appointment to the medical staff, for therapeutic diets and nutrition-related services if consistent with state law. For more information, review the practice tips below outlining the regulations and implementation steps for obtaining ordering privileges.
- Practice Tips: Hospital Regulation — Ordering Privileges for the RDN
- Practice Tips: Implementation Steps — Ordering Privileges for the RDN
State Operational Manual: Appendix A – Survey Protocol, Regulations, and Interpretive Guidelines for Hospitals (Rev 151, 11-20-15)
Sections §482.28(b). Menus must meet the needs of patients.
When comparing the revised 3-27-15 Section A-0629 to the 10-17-08 version, nutrition screening was removed and stronger assessment, intervention and care plan language for patients is included.
There is now an emphasis that a care plan for patients be identified especially for specialized nutritional needs and that it must address those needs. Monitoring of dietary intake and nutritional status must occur. Methods and frequency of monitoring could include patient weight=BMI, unintended weight loss or gain; intake and output; lab values.
§482.28(b)(2). All patient diets, including therapeutic diets, must be ordered by a practitioner responsible for the care of the patient, or by a qualified dietitian or qualified nutrition professional as authorized by the medical staff and in accordance with State law governing dietitians and nutrition professionals.
Section A-0630 changes reflect new diet-ordering privileges. Diets must be based on an assessment of the patient's nutritional and therapeutic needs and documented in the patient medical record (including documentation of the patient’s tolerance to any therapeutic diet ordered).
The Joint Commission
Effective July 2016, TJC has eliminated 319 elements of performance of the nearly 1,700 standards and elements of performance. Again, TJC is now aligned with the CMS regulations.
- Contact your TJC facility/organization Representative who handles TJC standards for current manual accreditation updates.
The following standards and element of performance within the Chapter – Provision of Care, Treatment, and Services need to be reviewed as these pertain to the functions of the RDNs and NDTRs.
- Standard PC.01.02.03: EoPs 1,2,3,6
- Standard PC.02.01.01: EoP 1
- Standard PC.02.01.03.
- Standard PC.02.01.05.
- Standard PC.02.01.21.
- Standard PC.02.02.01.
- Standard PC.02.02.01: EoP 1,2,3,17
- Standard PC.02.02.03: EoP 6,7,8,9,10,11
- Standard PC.02.03.01: EoP 1,4,5,10,25,27 – Note: EoP 10 – bullet on Nutrition interventions and modified diets
Note the standards and element of performance within the Chapter – Record of Care, Treatment, and Services especially RC.02.01.01 and EoP - Bullet 21.
Healthcare Facilities Accreditation Program
In 2015, HFAP eliminated the prescriptive determinants in their standards/elements and designed their program for the providers and organization to handle their own clinical workflow processes to meet their core business within their patient market.
- Contact your HFAP facility/organization Representative who handles HFAP standards for current manual accreditation updates.