August 2018 Comprehensive Review of Regulations & Interpretive - - PDF document

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August 2018 Comprehensive Review of Regulations & Interpretive - - PDF document

August 2018 Comprehensive Review of Regulations & Interpretive Guidance for Top F-Tags Activities of Daily Living F676-F677 Objectives 1. Identify the regulatory requirements 3. Identify examples of how F-Tags related to Activities of


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August 2018 www.proactivemedicalreview.com 1

Comprehensive Review of Regulations & Interpretive Guidance for Top F-Tags Activities of Daily Living F676-F677

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Objectives

1. Identify the regulatory requirements related to Activities of Daily Living 2. Identify survey procedures that describe how Activities of Daily Living requirements are reviewed for compliance during the annual survey process 3. Identify examples of how F-Tags related to Activities of Daily Living are commonly cited in the new LTCSP 4. Identify tools for the leadership team to use for monitoring compliance with Activities of Daily Living requirements 5. Explain strategies for incorporating survey preparedness related to Activities of Daily Living into facility QAPI processes

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regarding continuing education credits & certificates.

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Act Activities o ties of Da Daily L ily Living ng

Overview of F-Tag Regulations & Interpretive Guidance

Quality of Life Regulations

F483.24 Quality of Life F675 Quality of Life F676 Activities of Daily Living (ADLS)/Maintain Abilities F677 ADL Care Provided for Dependent Residents F678 Cardio-Pulmonary Resuscitation (CPR) F679 Activities Meet Interest/Needs of Each Resident F680 Qualifications of Activity Professional

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F676 - Regulatory Language

  • §483.24(a) Based on the comprehensive assessment of a resident and

consistent with the resident’s needs and choices, the facility must provide the necessary care and services to ensure that a resident's abilities in activities of daily living do not diminish unless circumstances of the individual's clinical condition demonstrate that such diminution was unavoidable. This includes the facility ensuring that: – §483.24(a)(1) A resident is given the appropriate treatment and services to maintain or improve his or her ability to carry out the activities of daily living, including those specified in paragraph (b) of this section …

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F676 - Regulatory Language

  • §483.24(b) Activities of daily living.
  • The facility must provide care and services in accordance with

paragraph (a) for the following activities of daily living: – §483.24(b)(1) Hygiene –bathing, dressing, grooming, and oral care, – §483.24(b)(2) Mobility—transfer and ambulation, including walking, – §483.24(b)(3) Elimination-toileting, – §483.24(b)(4) Dining-eating, including meals and snacks, – §483.24(b)(5) Communication, including

  • (i) Speech,
  • (ii) Language,
  • (iii) Other functional communication systems.

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F677- Regulatory Language

  • §483.24(a)(2) A resident who is unable to carry out

activities of daily living receives the necessary services to maintain good nutrition, grooming, and personal and oral hygiene; and

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Definitions

  • Oral Care

– Refers to the maintenance of a healthy mouth, which includes not only teeth, but the lips, gums, and supporting tissues. This involves not only activities such as brushing of teeth or oral appliances, but also maintenance of oral mucosa.

  • Speech, language or other functional communication systems

– Refers to the resident’s ability to effectively communicate requests, needs, opinions, and urgent problems; to express emotion, to listen to

  • thers and to participate in social conversation whether in speech,

writing, gesture, behavior, or a combination of these (e.g., a communication board or electronic augmentative communication device).

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Definitions

  • Assistance with the bathroom

– Refers to the resident’s ability to:

  • Use the toilet room (or commode, bedpan, urinal)
  • Transfer on/off the toilet
  • Clean themselves
  • Change absorbent pads or briefs
  • Manage ostomy or catheter
  • Adjust clothes

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Definitions

  • Transfer

– Refers to resident’s ability to move between surfaces

  • To/from:

– Bed – Chair – Wheelchair – Standing positions.

  • Excludes to/from bath/toilet

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F676 & F677 Interpretive Guidance

  • Conditions that may demonstrate an unavoidable ADL

decline:

– The natural progression of a debilitating disease with known functional decline – The onset of an acute episode causing physical or mental disability while the resident is receiving care to restore or maintain functional abilities – Refusal of care & treatment

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F676 & F677 Interpretive Guidance

  • Refusal of Care & Treatment

– Must document in medical record

  • Care planned interventions to minimize or decrease functional loss that

were refused by resident/representative

  • Any interventions that were substituted with consent of

resident/representative to minimize further decline

  • Attempts to identify underlying cause of the refusal

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F676 & F677 Interpretive Guidance

  • When unavoidable decline in ADLS occur, must:

– Identify interventions to assist resident – Immediately implement identified interventions

  • Appropriate treatment & services includes all care

provided to maximize resident’s functional abilities

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F676 & F677 Interpretive Guidance

  • Independent

– Completed activity with no help or oversight every time during 7-day look-back period

  • Supervision

– Oversight, encouragement or cueing provided 3 or more times during last 7 days

  • Limited Assistance

– Resident highly involved in activity & received physical help in guided maneuvering of limb(s) or other non-weight bearing assistance 3 or more times during last 7 days

  • Extensive Assistance

– While resident performed part of activity over last 7 days, weight bearing support provided 3 or more times or full staff performance of activity provided during part, but not all, of last 7 days

  • Total Dependence

– Full staff performance of an activity with no participation by resident for any aspect of the ADL activity. Resident was unwilling or unable to perform any part of the activity over entire 7-day look-back period.

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Activi tivities of es of Daily Daily Livin Living L LTC C Sur Survey Pr Procedur

  • cedures

es

Survey procedures for assessing compliance with the F-Tag and citation examples

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Initial Pool Process Resident Interview Care Areas

  • ADL Care Area

– Do you get the help you need to get out of bed or to walk? – Do you get the help you need when you need to use the bathroom? – Do you get the help you need to clean your teeth or get dressed? – Do you get the help you need during meals? – If not, please describe.

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Initial Pool Process Resident Interview Care Areas

  • ADL Decline Care Area

– Has your ability to dress yourself or to take a bath changed?

  • If so, please describe.

– Has your ability to get to the bathroom or use the bathroom changed?

  • If so please, describe.

– Do you need more help now to clean your teeth or eat meals? – Do you need more help with getting out of bed or walking now?

  • Has this been happening for a long time?
  • About how long?

– What are staff doing to stop you from getting worse or to help you improve in these areas?

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Initial Pool Process Resident Interview Care Areas

  • Vision & Hearing Care Area

– Do you have any problems with your vision or hearing? – Do you wear glasses or use hearing aids? – Are your glasses and/or hearing aids in good repair? If not, what are the facility staff doing to help you with this problem? – Do you need glasses or a hearing aid? – Have you lost your glasses or hearing aids at the facility? – What did the facility do if you lost them? – Does the facility help you make appointments and help with arranging transportation? – If resident has either/both - how are they working for you?

Initial Pool Process Resident Observation

  • Language/Communication Care

Area

– Does the resident speak a different language, use sign language or other alternative communication means? – Does staff know how to communicate with the resident? – Are there communication systems available at the bedside (cards, note pad, others)?

  • ADLS Care Area

– Are any of the following observed?

  • Hair disheveled, uncombed or greasy
  • Facial hair unkempt or present on a

female resident

  • Face, clothing or hands unclean or with

food debris

  • Fingernails untrimmed, jagged or dirty
  • Body or mouth odor
  • Teeth or dentures not brushed
  • Clothing visibly soiled or in disrepair
  • Dentures stored in an unsanitary manner,

if visible

– If the situation presents itself, are there

  • ther concerns with the assistance

provided for other ADLs (e.g., dressing

  • r transfers)?

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Initial Pool Process Limited Record Review

  • ADL Decline

– Has the resident had a decline in their bed mobility, transfer, eating or toilet use recently and is not receiving therapy or restorative for the decline in the last 120 days?

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Activities of Daily Living (ADL) CE Pathway (CMS-20066)

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Communication & Sensory CE Pathway (CMS-20069)

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Dining Observation CE Pathway (CMS-20053)

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Specialized Rehabilitative or Restorative Services CE Pathway (CMS-20080)

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ADL Surveyor Focus

  • Did facility:

– Recognize and assess an inability to perform ADLs, or a risk for decline in any ability they have to perform ADLs? – Develop and implement interventions in accordance with the resident’s assessed needs, goals for care, preferences, and recognized standards of practice that address the identified limitations in ability to perform ADLs? – Monitor and evaluate the resident’s response to care plan interventions and treatment? – Revise the approaches as appropriate?

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F676 Activities of Daily Living (ADLS)/ Maintain Abilities Survey Trends

  • 326 citations

– Complaint Surveys = 79 – Standard Surveys = 247

  • Scope & Severity

– B level = 2 – D level = 265 – E level = 53 – G level = 6

  • The is valid for the subset of providers for which there are

survey records in CASPER as of 7/30/18 Source: S&C QCOR (08/06/2018)

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F676 G Level Citation Example - IL

  • Facility failed to provide timely reassessment, monitoring and

services to maintain and/or improve ambulation abilities for

  • ne of 21 residents reviewed for activities of daily living in the
  • sample. This failure resulted in Resident declining in

ambulation from 200 feet to barely making steps

– Resident was on walk to dine restorative program. Surveyors

  • bserved resident being propelled to dining each day of survey and

staff & wife voiced has had decline and unable to ambulate

  • anymore. Daily documentation that walk to dine performed daily

during month (including dates of survey when observed not to

  • ccur). Referral was not made to therapy r/t decline until surveyors

questioned regarding actions taken in response to decline

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F676 G Level Citation Example - MI

  • The facility failed to provide the care and services to prevent physical decline for 1
  • f 28 residents reviewed for care, resulting in Resident having an avoidable decline

in walking and physical movement – Resident could walk 170 feet with a 2 wheeled walker and one person assist when Physical Therapy discharged him on 6/8/17. Could not find the standard documentation that was provided to nursing with instructions to help maintain a Residents function when discharged from therapy or any documentation that would explain why nursing did not receive any instructions to continue to walk with him when discharged from therapy on 6/8/17. – Per 1/18 MDS, was non-ambulatory & required extensive assist of 2 with transfers. On 2/8 surveyors observed him being transferred with hoyer lift & 2 assist (total dependence). Multiple observations made of him being up in Geri-chair throughout day. He voiced it was uncomfortable & he wanted to go to bed. Staff informed surveyors he was to be left up in Geri chair because if in bed he would attempt to stand & fall. Care planned intervention following fall when he attempted to stand up from geri chair in Dec 2017 was to keep chair reclined while he was in it. It was not coded as a restraint.

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F676 G Level Citation Example - MN

  • Facility failed to provide restorative/maintenance services to prevent the

loss of ambulation ability for 1 resident who was reviewed for a decline in

  • ambulation. Resident sustained actual harm when the facility failed to

assess for and implement a restorative/maintenance services and can no longer ambulate.

– Upon admission received PT/OT for 2 weeks r/t amputation & prosthesis. (was DC’d after 2 weeks d/t payor only approved set amount of sessions per year). When DC’d was ambulating using prosthesis & walker with therapy – Upon DC from therapy, was not placed on any nursing program to continue working on ambulation & prosthesis, nor was prosthesis use care planned. – Resident was not ambulated at all following therapy DC & experienced muscle wasting & prosthesis no longer fit. – Facility did not have restorative program in place or good therapy to nursing communication to facilitate transitions from therapy to nursing care.

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F676 G Level Citation Example - OH

  • Facility failed to ensure residents who can self-feed and ambulate with limited

assistance received the services necessary to maintain their highest level of

  • independence. Actual harm occurred to Resident #24 when no ambulation program

was implemented and the resident's ability to ambulate declined from supervision to extensive assistance. In addition, Resident #11 ability to self-feed was not maintained as staff fed the resident. – RI 24 required supervision to limited assist with ambulation when DC’d from therapy. Nursing staff was educated to maintain current level of ambulation. No care plan developed to maintain resident’s ambulation status. She was in a w/c with seatbelt & alarms and staff did not ambulate her on routine basis & declined to requiring extensive assistance with ambulation. (staff stated required seatbelt at all times because she would wander into other rooms) – RI #11 had a goal of feeding self 50% of meals with moderate/maximum assistance. Surveyors observed staff feeding him & tray out of his reach so he could not attempt to feed himself

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F676 G Level Citation Example - OH

  • Facility failed to implement a comprehensive and individualized

restorative ambulation program to maintain or improve Resident #5's ambulation ability following the resident's discharge from therapy.

– Actual Harm occurred when Resident #5, who was discharged from physical therapy on 09/13/17, with the ability to walk between 125 and 150 feet with caregiver assistance declined and was only able to walk 50 feet with caregiver assistance. The facility failed to provide evidence a comprehensive and individualized restorative nursing program was developed and implemented and the resident had an avoidable decline in ambulation.

  • Resident picked up by therapy multiple times during stay d/t declines.
  • No formal restorative program in facility & concerns voiced that care plan to walk to

nurses station and back daily was not followed /t staffing issues

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F676 G Level Citation Example - TX

  • Facility failed to provide the necessary care and services to ensure that

a resident's abilities in activities of daily living do not diminish, based on the comprehensive assessment and consistent with the resident's needs and choices, for 1 resident reviewed for ADLs

– Resident said her orthopedic surgeon sent instructions for therapy to the

  • facility. When she went for a follow up with her doctor 3 weeks later and the

doctor found out the therapy wasn't started as she had ordered. The doctor didn't want the sling on all the time, but it was. She didn't have any exercises done with her left arm when she should have been having them. Her elbow got so stiff she couldn’t lift her lower arm at all. The doctor said she might not get the full use of my arm back. She said it caused her pain and she is still taking pain pills occasionally.

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F677 ADL Care for Dependent Residents Survey Trends

  • #12 most frequently cited F-tag in STD surveys
  • 1,389 citations

– Complaint Surveys = 406 – Standard Surveys = 983

  • Scope & Severity

– B level = 5 – D level = 987 – E level = 386 – F level = 2 – G level = 7 – H level = 1 – I level = 1

  • The is valid for the subset of providers for which there

are survey records in CASPER as of 7/30/18 Source: S&C QCOR (08/06/2018)

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F677 Harm (I) Level Citation Example - MI

  • Facility failed to reposition 13 dependent residents

according to the facility policy resulting in the development

  • f stage I to stage IV pressure ulcers.

– Care plans were not updated timely to include appropriate interventions according to the facility repositioning policy

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F677 Harm level Citation Example - OH

  • Facility failed to provide the required staff assistance for

Resident to eat meals. Actual harm occurred when staff failed to feed Resident resulting in a significant weight loss of 15.41% in the last 180 days.

– Care planned for physical assistance with meals. Per flow sheet records, only received set up assistance with meals & staff did not physically assist him to eat food. Nothing was recorded to indicate how much of his meals he ate. – Surveyors observed him not eating meals during survey & staff not providing assistance to eat

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F677 Harm Level Citation Example - OH

  • Facility failed to ensure residents who required assistance for activities of daily living

received timely and necessary care to maintain adequate personal care and hygiene. Actual harm occurred to Resident when State tested Nursing Assistant (STNA) entered Resident's room, found the resident crying and upset and identified the resident had a large amount of stool that was dried to her skin. The resident's buttocks were observed to be red and starting to open. Resident informed STNA she had not been checked on by staff all night. – The resident stated she was aware of when she needed to use the bathroom to move her bowels. The resident stated a few days prior she had to move her bowels and was unable to activate her call light due to the placement of the call light and the light being wrapped around her right arm. The resident stated the door to her room was closed and since she was unable to reach her call light, she started to yell out. She stated she waited and waited, however, no staff came. The resident stated because no one came, she laid in feces all night. The resident stated this caused her skin to breakdown and she was very sore. The resident said she told her husband, when he came in that morning and he immediately shared the concerns with the Administrator. Further interview revealed by the time she was discovered the following morning, she was crying and upset because she felt scared and felt no one was there to care for her. (NHA submitted self report for allegation of neglect) – Other areas noted in citation were residents not provided assistance with oral care as needed, baths not documented as completed per care plans, dirty finger nails, & facial hair

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F677 Harm Citation Example - CO

  • Facility failed to ensure one resident received the care and services

with bathing she was assessed to need and ordered to receive to maintain good grooming and personal hygiene. Specifically, for a number of months, the facility failed to provide the resident showers three times a week as ordered as well as the assistance she was assessed to need when she was showered. These failures contributed to resident odors, the resident's nonparticipation in facility activities and feelings of embarrassment, shame, depersonalization, and self-disgust.

– Care plan did not document guidance on her preferences or need for assistance for showers. (she required extensive assist with bathing) – Resident stated staff do not offer or assist her with shower 3X per week & bathing records showed less than one shower occurring weekly.

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F677 Harm Citation Example - WA

  • Facility failed to ensure 1 resident received the necessary care and services to maintain

good oral hygiene. The failed practice cause harm to Resident who experienced significant plaque build-up, bleeding gums and oral pain. – Resident with developmental delay diagnosis & severe cognitive impairment – Care plan directed staff to set the resident up twice daily and as needed for oral care (12/17) & was updated in past 2 weeks (01/18) to indicated required physical assist of one with brushing teeth – Had poor oral care documented by the dentist at each visit over the course of the past year (6/17 & 10/17, 1/18). The assessment stated the resident had a broken bridge, and the dentist would not replace the bridge until the resident could show good oral care. Resident dislikes missing teeth very much and does want the bridge replaced . The assessment concluded the nursing staff would have more success if they were taught strategies specific for Resident and if the staff was aware of the severity of the resident's oral concerns. Dentist ordered brushing 2X day & swish & spit at each visit. – Guardian expressed concerns regarding oral care at multiple care conferences and felt staff did not

  • address. Also when she asked staff to show bottle of medication ordered to swish & spit, it was still

full. – The behavior assessor identified how important the bridge was to the resident. The facility failed to implement the behavior assessors plan or participate in training to improve the resident's oral care.

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F677 Harm Citation Example - CA

  • Facility failed to provide ADL care for a dependent

resident when the care plan of having two people during a shower for one resident was not implemented. This resulted in first degree burn of the left side of Resident's face and left side of Resident's chest while being showered with only one staff present.

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F677 Harm Citation Example - CA

  • The facility failed to ensure residents who are not able to carry out activities of daily

living (ADLs) received the necessary services to maintain good nutrition, grooming and personal hygiene for six sampled residents who were not assisted with eating, personal hygiene, and mobility due to insufficient Certified Nursing Assistants (CNAs). This deficient practice resulted in weight loss for 2 residents, pressure ulcer for one, lack of mobility for 2 residents, and lack incontinent care for 5 Residents. (Also received IJ at F725 that was cross referenced to this citation) – Facility failed to provide resident a w/c & she was no longer able to participate in activities she enjoyed & if requested to get up, it took staff hours before they would get her up – Observed nourishment shakes on resident bed side table that were not cold & no staff assisting to drink them. Also observed him yelling for staff to assist with putting food in his mouth & tray laying at bedside with no staff preset (care planned to be fed by staff). Resident had significant wt loss – Residents with pressure ulcers who did not receive timely incontinence care or mobility assistance

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Activi tivities of es of Daily Daily Livin Living QAPI QAPI

Strategies for monitoring compliance and incorporating survey preparedness into facility QAPI processes

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ADL Focused Committee

  • Interdisciplinary review of changes in ADLs/declines in function
  • Monitoring short-stay residents for targeted improvements in

function

  • Identify root causes & risk factors
  • Analyze trends
  • Review therapy/restorative data

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Data Analysis

  • Chronic Conditions
  • Exercise Programs
  • Restorative Nursing/Maintenance Outcomes Data

(success in reducing declines)

  • Therapy screens/conversions

QAPI PIP Ideas

  • Restorative

Programs

  • Alarm Use

Reducing Mobility Declines

  • ADL Coding

Accuracy

  • Dining Room
  • Environmental

Safety

  • Identifying

Changes in Condition

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Achieve Excellence!

  • Provide ADL training to all nurses and CNAs upon hire

and at least annually

  • Document multiple times throughout the shift; point of

service documentation

  • Establish a system for the MDS nurse to validate ADL

coding and facilitate ongoing training

  • Select a nurse and CNA champion who serve as

mentors for accurate ADL coding

  • Develop system for monitoring for ADL declines

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References

1.Centers for Medicare and Medicaid Services. (2017). Nursing homes‐ Centers for Medicare and Medicaid Services. Retrieved from https://www.cms.gov/Medicare/Provider‐Enrollment‐ and‐Certification/GuidanceforLawsAndRegulations/Nursing‐ Homes.html 2.Centers for Medicare & Medicaid Services. (2017). S&C QCOR Home Page. Retrieved from https://pdq.cms.hhs.gov/report_select.jsp?which=0

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Questions?

Type your questions using tool bar on right of your screen. Please register to join us in August for the next session in the F-tag series: Resident Assessment/Accuracy of Assessments

Shelly Maffia, RN, MSN, HFA, MBA, QCP smaffia@proactivemedicalreview.com Proactive partners with SNF providers for regulatory compliance, training, & medical review solutions.