Opinion Piece: Lou Ann Brubaker Shares Insights on Supporting SNF Clients’ Regulatory Performance
In July during a virtual coffee chat with one of my pharmacy clients, we explored COVID-19 and its tremendous impact on stress levels within the nursing staff.
The topic of our next conversation was made easy by the Centers for Medicare and Medicaid Services (CMS) August 2020 announcement that SNF surveys would resume immediately. In these chats, we typically explore how his pharmacy could be even more supportive of SNF challenges—this time in respect to the regulatory environment.
We began with a quick recap of what was put in motion nearly 4 years ago with The Mega (or Final) Rule. Starting in 2016, CMS began the most sweeping regulatory changes in decades. No SNF department was left untouched.
I described the good news: these new regulations were implemented in three phases, which gave SNFs the opportunity to catch their breath and then methodically put in place new processes. In each phase, there has been a valuable role for pharmacy in areas as diverse as; psychotropic drug use, behavioral health, infection control, re-hospitalizations, and emergency response.
He then asked if regulatory compliance had gotten substantially harder under the new process. I said the answer is both yes, and no.
Yes, because there are ever more stringent requirements for Medicare and Medicaid participation.
No, because under the updated guidance to surveyors, I believe nursing homes have a much greater idea of surveyors’ targets during inspections and how to better prepare.
A good example of this is the over three-dozen resources CMS has created which give insight into the questions surveyors will be asking--and of whom. Medications are mentioned in nearly half of these tools. These can serve as catalysts for robust and productive conversations with facility clients as part of a pharmacy’s ‘value-add’. Pharmacies should use them to fuel their internal operations and consulting discussions as well. I find them to be an objective and authentic opportunity for a pharmacy to evaluate, “How do we…” with respect to its regulatory compliance support.
He asked whether surveys now have greater ramifications in facility success. I said,
“Absolutely. They’re one of three key factors driving a facility’s five-star rating. I find they affect staff recruitment and retention. Prospective facility leadership and front-line managers perform due diligence regarding surveys, quality measures, and staffing before considering a position.
Especially crucial is how surveys impact occupancy and payer sources. The Patient-Driven Payment Model (PDPM) that replaced the Prospective Payment System (PPS) last October remains a fee-for-service program.
More and more third-party payers will control the Medicare dollars. Each one reviews years of survey performance before considering a SNF as a program participant. SNFs without a seat at this table risk being cut out of a steady stream of higher-revenue, higher-margin admissions.
The percentage of SNFs being rejected as participants by the growing Post-Acute Networks (PANs) is breathtaking. Recently one on the East coast chose 19 SNFs out of 266 applicants. Pharmacies whose software enables positive outcome collaborations and also provides their clients with vital PAN decision-making data have a marketable competitive advantage."
I believe my client is representative of long-term care pharmacy’s commitment to assuring quality care and quality of life for facility residents. He, like other pharmacy leaders I know, is profoundly curious about changes impacting his own clients and how he can respond in meaningful ways.
My spirit always feels buoyed after a conversation like this.
Learn more
Hear more from Lou Ann as she returns to the 20th Anniversary Webinar Series stage for a live webinar on Thursday, November 5th at 2pm ET. Lou Ann's presentation, "Supporting Skilled Nursing Facility Compliance: Enhancing Your Pharmacy's Value to Clients," will cover how to help your SNF clients with their surveys and strategies to demonstrate your LTC pharmacy's value proposition.
About our guest author, Lou Ann Brubaker, President of Brubaker Consulting:
Lou Ann Brubaker is a highly accomplished Senior Healthcare Consultant, Entrepreneur, and Educator with more than 30 years of success in the post-acute care marketplace. She is the President and Founder of Brubaker Consulting.
Leveraging extensive experience working with senior care professionals, ranging from C-suite to the front-line, Lou Ann is a valuable asset for healthcare organizations across the provider continuum in achieving their financial, occupancy, and staff recruitment/retention goals.
The views and opinions expressed on The LTC Innovation Blog are those of the authors and do not necessarily reflect the official policy or position of SoftWriters, Inc. Any content provided by our bloggers or authors are of their opinion and are not intended to malign any religion, ethnic group, club, organization, company, individual or anyone or anything.