If you work in a facility that accepts Medicare and/or Medicare reimbursement, you likely know that CMS has revised its State Operations Manual (SOM) regulations. These revisions are detailed in a CMS survey and certification memo [PDF]. They come on the heels of a 2015 memo [PDF] that provides an overview of the CMS’s Focused Dementia Care Survey, also referred to as the dementia focused survey.
An iAdvanceSeniorCare.com article by Judi Kulus of the AANAC outlines the top 10 revised rules, also called F-tags and deficiency tags. Here is our guidance on the top 10, plus information on howwith evidence-based, person-centered, best-practice solutionswe can help you ensure compliance and avoid fines and citations.

Rule 10: Facility sound levels

The Rule
This rule requires staff to regularly assess the hearing needs of residents with dementia and how residents are affected by the sounds of stimuli such as traffic, music, equipment, staff behavior, and other residents.
The Solution
Among many tools, our Dementia Design Scorecard can help you assess how dementia-friendly your facility is. With this tool, you can assess the therapeutic quality of your environment, how much sound disruption you’re dealing with, the quality of your caregiver support, and much more.

Rule 9: Facility Policies and Procedures

The Rule
The SOM includes a new list of 7 required policies and procedures such as staff training on dementia management and the prevention of resident abuse, neglect, and exploitation. Under this rule, your policies and procedures should have “screening, training, prevention, identification, investigation, protection, and reporting/response” components.
The Solution
Our Warchol Best Abilities Care ModelSM is designed to help you develop best-practice policies and procedures. Built to help you implement high quality training, the model gives you behavior management tools plus a structure for activities, ADLs, and daily routines. The Core Package includes tools and training to help you use the information you gather from assessments to build care around each resident’s preference, promote each resident’s optimum level of independence, create customized care plans, and identify your staffing needs and plans.
Core Package features include:
  • Training in how to conduct evidence-based, person-centered assessments. This includes our Life Story Questionnaire [PDF], Activity Interest Survey, and Dining Survey.
  • Training in how to conduct functional cognition assessments. This includes the Cognitive Assessment Tool Guide (CATG), Adapted FAST, and Crosswalk Comparison Tool.
  • Care plan tools such as the General Care Plan Template, the General Service Plan Guide, and the High Risk Guide.
  • Dementia Capable Care staff training, procedures, and hiring tool.

Rule 8: Activities of Daily Living

The Rule
Aimed at reducing excess disability, this rule requires facilities to provide “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.”
The Solution
We’re here to help you maximize your residents’ best ability to function. DCS gives you tools to customize activities of daily living to each person’s needs, preferences, and stage-specific cognitive ability.

To meet each resident’s needs and preferences, download our Life Story Questionnaire [PDF].

To provide stage-specific care, explore Dementia Capable Care staff training.

Rule 7: Social Services

The Rule
This rule requires your facility’s social services professionals to be integrally involved in evaluating the root causes of aggressive behaviors and in preventing resident-to-resident aggression.
The Solution
Our Warchol Best Abilities Care ModelSM tools are designed to help all your staff with behavior management, aggression prevention, incident reporting and assessment, and quality assurance. Among many tools in our Behavior Toolkit are a Behavior Observation Log, Behavior Management Plan, Behavior Response Card, pocket-sized Behavior Job Aids, and A Cognitive Link: Managing Problematic Bodily Behaviors.

Rule 6: Activities

Photo: diego_cervo / iStock

The Rule
The Activities section of the SOM has been revised to read:
“The facility must provide, based on the comprehensive assessment and care plan and the preferences of each resident, an ongoing program to support residents in their choice of activities, both facility-sponsored group and individual activities and independent activities, designed to meet the interests of and support the physical, mental, and psychosocial well-being of each resident, encouraging both independence and interaction in the community.”
The Solution
It’s essential for leisure, social/group, and independent activities to be person-centered and stage-specific. 
Our Warchol Best Abilities Care ModelSM includes an Activity Toolkit with guidelines, calendar templates, activity protocols, an Activity Interest Query Tool, our Activity Planning Book, and Dementia Capable Care: A Best-Abilities Approach DVD.
To learn each resident’s likes and dislikes when it comes to activities and much more, download our Life Story Questionnaire [PDF].

For a sample of recommended arts and crafts activities, browse an excerpt of our Activity Planning Book.
To put this all into action, you’ll need training and activity program infrastructure.

Rule 5: Proficiency of Nursing Assistants/Staff

The Rule
“Competency of staff to care for cognitively impaired residents is in surveyors’ bull’s-eye,” reports Judi Kulus in the iAdvanceSeniorCare.com article.
This CMS rule requires your facility to provide dementia management training and resident abuse prevention training. Your facility must “employ sufficient staff with the appropriate competencies and skills sets to carry out the functions of the food and nutrition service, taking into consideration resident assessments, individual plans of care and the number, acuity and diagnoses of the facility’s resident population in accordance with the facility assessment.
The Solution
Dementia Capable Care training is recognized by the Alzheimer’s Association for meeting their Dementia Care Practice Recommendations. In fact, it’s the only Alzheimer’s Association-reviewed training that meets the guidelines in all 10 categories [PDF]. Because providing the highest quality memory care begins with your front line staff, Alzheimer's training for CNAs--as well as nursing, technical and administrative staff--is central to Dementia Capable Care training. 
Also with Dementia Capable Care training, your staff can achieve our Dementia Care Specialist Certification.
Additionally, the Warchol Best Abilities Care ModelSM includes Audit Tracking Tools, QA/QI Tools, and Onboarding New Member Tools.

Rule 4: Dignity

Photo: mikyso / iStock

The Rule
This rule requires:
  • Privacy during care.
  • Staff to respond in a dignified manner to residents with cognitive impairments.
  • Staff to look for causes of difficult behaviors.
  • Staff to preserve a resident’s dignity by validating their world, rather than orienting them to the present time and place.
The Solution
Dementia Capable Care training teaches that dignity is a feeling and that care partners have the power to influence how a person with dementia feels about themselves.

Rule 3: Unnecessary Drugs

The Rule
This rule emphasizes the importance of non-pharmacological interventions. It also stipulates, according to the iAdvanceSeniorCare.com article, that “residents are not to receive PRN antipsychotic medications unless for a specific, documented diagnosis. PRN orders for psychotropic drugs must not be given beyond 14 days without the prescribing practitioner documenting the rationale. Time frames for continued PRN use must be documented in the medical record.”
The Solution
Dementia Capable Care training equips nursing home providers and care partners with skills to tune in to the individual needs, desires, and perspectives of their residents with dementia to find alternative methods of behavior management.
You can explore non-pharmacological interventions by reading DCS president Kim Warchol’s article about the DRNO protocol and how to use it. This protocol details how to:
  • Describe the Behavior Expression
  • Uncover the Reason
  • Identify Appropriate Non-Pharmacologic Intervention(s)
  • Observe Outcomes of Chosen Intervention(s)

Rule 2: Quality of Care

Photo: FredFroese / iStock

The Rule
This rule details 61 pages worth of Quality of Care requirements for surveyors to look for. To meet this requirement, your facility must have a comprehensive dementia care program in place.
The Solution
If you don’t yet have a fully comprehensive program in place, implement our complete Warchol Best Abilities Care ModelSM to meet this need.
If you’re on the right track and you just need to round out an existing, in-house, or branded program that you already have in place, you can implement select components of the Warchol Best Abilities Care ModelSM to improve or enhance any aspects in your programming that need improvement.

Rule 1: Facility Assessment

The Rule

This rule requires every nursing home to develop a comprehensive facility assessment by November 28, 2017.

According to the CMS memo, this will help your facility “determine what resources are necessary to care for its residents competently during both day-to-day operations and emergencies.”

By definition, writes Judi Kulus in the iAdvanceSeniorCare.com article, “the facility plan must include the facility’s dementia management programs. After analyzing their resident population, facility leaders must detail residents’ needs, required staff competencies, physical environmental needs, emergency response and much more.”

The Solution
Our Facility Assessment solution, available through our consulting services, can help you meet this requirement. Our Dementia Design Scorecard can get you started too.

Start Now!

We’re here to help you implement evidence-based, person-centered best practices in dementia care.

Most importantly, we’re here to make it easier for you to provide the highest quality of care for our elders, who deserve respect and dignity. The resources in this article will help you get started.
Have questions? Need to ensure your compliance?

Give us a call at 888.426.2184. We look forward to helping you achieve compliance and discover even more ways to help every person in your care experience function, joy, and quality of life.