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CMS ESRD Conditions for Coverage: Review and Questions Alex Rosenblum RN, VP Quality SWBU – Fresenius Medical Care The Stephen Z. Fadem Update Professional Symposium February 27, 2009 CONDITIONS FOR COVERAGE Provide an opportunity for Q&A related to specific practice areas
Alex Rosenblum RN, VP Quality SWBU – Fresenius Medical Care
The Stephen Z. Fadem Update
February 27, 2009
Provide an opportunity for Q&A related to specific practice areas
These questions have been called into the regulatory department of a large dialysis organization and will be discussed here
The ESRD Conditions for Coverage are the minimum health and safety rules that all Medicare and Medicaid participating dialysis facilities must meet. The April 15, 2008 ESRD Conditions Final Rule modernizes Medicare's ESRD health and safety conditions for coverage and updates CMS standards for delivering safe, high-quality care to dialysis patients. The revised regulations are patient-centered; reflect improvements in clinical standards of care, the use of more advanced technology, and, most notably, a framework to incorporate performance measures viewed by the scientific and medical community to be related to the quality of care provided to dialysis patients.
Part A: General
Part B: Patient Safety
Hepatitis really very, very important to understand –
Can we place hand sanitizers on the side of the dialysis machines?
If a computer data entry screen is located away from the patient area, what are the infection control requirements?
Can sinks used to drain saline bags, disinfect clamps and/or prime buckets be used for handwashing?
If a facility has an isolation room, may they refuse to accept HBV+ patients, so that the isolation room can be used as a regular station and used for all shifts?
If the HBV+ patient runs 2X week only and the room is terminally cleaned and the machine removed, why can’t the room be used for HBV- patients?
What supplies should be kept in an isolation room or area?
Building/furnishings/equipment - safe and functional
All equipment operated according to manufacturer’s guidelines
Patient care environment sufficient prevent cross contamination and accommodate emergency equipment
Accommodations patient privacy
Patient/staff education and training
Notification local “Disaster Management Agency”
What are the expectations for refrigerators for medication storage?
Does the “no video surveillance” apply to nocturnal dialysis?
What if the patients’ refuse to keep their vascular accesses uncovered? Is having the patient sign a waiver acceptable?
Patient rights and quality of care :
As long as you provide education to the patient and document it you should be fine on patient rights. The CMS answer is that while you are making walking rounds, get the patients approval to discuss clinical issues. Do not talk about sex, financial or HIV issues. It is permissible to talk about phosphorus. Alternative is that patient must come to a meeting outside the treatment area, and most will be reluctant to do so.
What ever you do for center, you must do for home and home care patients. Assessments, visit, QAPI.
* Texas Licensure Regulations
QAPI is the medical director’s responsibility. What CMS surveyors are claiming is that there must be a process in place. What is the description, what is the scope – how are you tracking, recognizing?
IN ORDER FOR THE MEDICAL DIRECTOR TO EVERYTHING THEY ARE SUPPOSED TO DO THEY HAVE TO BE PRESENTED IN QAI EVERYTHING. THERE ARE CITATIONS THAT MEDICAL DIRECTOR DID NOT ENSURE THAT THE FACILITY STAFF WERE FOLLOWING POLICY AND PROCEDURE. WHEN THE SURVEYORS SEE A BREAK IN PROCEDURE THEY CITE THE MEDICAL DIRECTOR BECAUSE HE HAS NOT ASSURED IT. THE WAY HE CAN BE ABLE TO ASSURE IT IS THAT IT IS IN THE QUALITY ASSESSMENT/IMPROVEMENT MEETING.
The world has changed – it is not the tag, but the doctor. It is critically important that the doctor know what is going on. Doctors must attend surveys. Make sure you review all results with them.