Rural Health Clinic Survey and Recertification

1. Rural Health ClinicSurvey and Recertification IRHA June 11,2014 Presented by: BethAnn Perkins, RN, Principal

2. Objectives • Able to identify 5 of the top ten survey deficiencies • Identify ISDH recertification pitfall that can cost you the most • Name 3 processes that you must have in place to keep you from a condition level deficiency

3. AAAASF/RHC & ISDH • American Academy for Accredited Ambulatory Surgical Facilities • Perform Initial RHC Certification surveys on behalf of the State. • You submit an accreditation application to AAAASF and your RHC State application to ISDH • Survey results are forwarded to ISDH for review and submission to CMS. • ISDH does not do any initial RHC surveys but they are responsible for recertification surveys if they performed your initial certification survey. • Process initial survey package once results are received from AAAASF/RHC.

4. Standard vs. Conditions

5. Top Cited Deficiencies

6. Top Cited Deficiencies

7. Top Cited Deficiencies

8. Top Cited Deficiencies

9. Re-certification Citations from ISDH • 491.6(b) Maintenance • 491.8 Staffing and Staff Responsibilities • 491.9(b) Patient Care Policies • 491.10 Records System • 491.11 Program Evaluation

10. Top Citation from ISDH • 491.6 Physical plant and environment – (b) Maintenance • The clinic has a preventive maintenance program to ensure that: • (1) All essential mechanical, electrical and patient-care equipment is maintained in safe operating condition; • (2) Drugs and biologicals are appropriately stored; and • (3) The premises are clean and orderly. • 491.8 Staffing and staff responsibilities • (b) Physician responsibilities • (c) Physician assistant and nurse practitioner responsibilities.

11. Top Citation from ISDH • 491.9 Provision of services – (b) Patient care policies • The clinic has a preventive maintenance program to ensure that: • (1) The clinic’s health care services are furnished in accordance with appropriate written policies which are consistent with applicable law. • (2) The policies are developed with the advice of a group of professional personnel that includes one or more physicians and one or more physician assistants or nurse practitioners. At least one member is not a member of the clinic staff. • (3) The policies include: • (i) A description of the services the clinic furnishes directly and those furnished through agreement or arrangement. • (ii) Guidelines for the medical management of health problems which include the conditions requiring medical consultation and/or patient referral, the maintenance of health are records, and procedures for the periodic review and evaluation of the services furnished by the clinic. • (4) These policies are reviewed at least annually by the group of professional personnel required under paragraph (b)(2) of this section and reviewed as necessary.

12. Top Citation from ISDH • 491.10 Patient health records • (a) Records system. • (1) The clinic maintains a clinical record system in accordance with written policies and procedures. • (2) A designated member of the professional staff is responsible for maintaining the records and for insuring that they are completely and accurately documented, readily accessible, and systematically organized.. • (3) For each patient receiving health care services, the clinic maintains a record that includes, as applicable: • (i) Identification and social data, evidence of consent forms, pertinent medical history, assessment of the status and health care needs of the patients, and a brief summary of the episode, disposition, and instructions to the patient. • (ii) Reports of physical examinations, diagnostic and laboratory test results, and consultative findings; • (iii) All physician’s orders, reports of treatments and medication, and other pertinent information necessary to monitor the patient’s progress.

13. Top Citation from ISDH • 491.10 Patient health records • (b) Protection of record information. • (1) The clinic maintains the confidentiality of record information ad provides safeguards against loss, destruction or unauthorized use • 491.11 Program evaluation • (a) The clinic carries out, or arranges for, an annual evaluation of its total program. • (b) The evaluation includes review of: • (1) The utilization of clinic services, including at least the number of patients served and the volume of services. • (2) A representative sample of both active and closed clinical records; and • (3) The clinic’s health care policies • (c) The purpose of the evaluation is to determine whether: • (1) The utilization of services was appropriate; • (2) The established policies were followed; and • (3) Any changes are needed. • (d) The clinic staff considers the findings of the evaluation and takes corrective action if necessary.

14. 5 Processes to Implement • Develop a comprehensive Preventative Maintenance Program that includes: • Management of equipment (annual inspection, calibration, daily inspection, process of repair and removal) • Develop Bi-directional Physician Review process. • Process is written and includes an accounting of the nurse practitioner’s prescribing DOS

15. 5 Processes to Implement • Establish annual review of all policies • Staff review (initially the nurse practitioner/physician assistant must participate in the development of the policies or at the very least have the opportunity to provide input and comment on existing policies. • For provider-based practices, policies must reflect the operations of the clinic. • Professional Advisory Group approval of reviewed policies • Management of equipment (annual inspection, calibration, daily inspection, process of repair and removal) • Develop annual review of medical records including inactive records (patients who have transferred, died, or not seen in the clinic with the past 3 years); develop ongoing compliance audit

16. 5 Processes to Implement • Develop written Program Evaluation • Ensure completed annually • Utilize Road Map, ensure that all components are reviewed and commented on • Professional Advisory Group must include: • Medical Director • Physician Assistant/Nurse Practitioner • Community Member

17. Thank You!Indiana Rural Health Association BethAnn Perkins, RN Health Consulting Strategies, Inc. www.healthconsultingstrategies.com