F658, formerly known as F281, are frequently cited deficiencies. Under these F-tags, the expectation seems simple; that the services be provided or arranged for that meet professional standard of care. Why is this cited so often? Are staff members improperly trained (sufficient and competent staff), policies and procedures are not effective, thorough, or current (compliance and ethics – written standards), or in some situations, are providers not setting expectations as leaders and enforcing a culture of compliance within the organization? There may be any number of reasons why these citations occur, and in some cases, it may just be an off-day for staff members. Nonetheless, professional standards are one area where management can deploy internal oversight and drive improvement somewhat easily.
Conducting a root cause analysis (QAPI) and leveraging CMS survey tools to test internal policies, training, and oversight; and to audit staff members on an ongoing basis makes sense.
While this F568 covers much more than standards of practice related to medication administration, a recent example of this citation was related to medications being left at the bedside. This CMS Medication Administration Observation form is the guide that is used by surveyors when they conduct medication pass observations. This provides a methodical way to observe staff members while administering medications via different routes (oral, NG, injections, ophthalmic, inhalers, etc.). This form also includes a testing element asking the surveyor/observer if the staff member ensured medications were administered to the resident (and not left at the bedside).
Using this form as an auditing tool may cause you to identify issues while observing your staff members. It is a good idea for a provider to look back on their policy and procedure and training and competencies to help identify where the breakdown or systemic failure occurred. Another key consideration is to make sure the person conducting the internal observation is well-versed in professional standards and the contents of your policy and procedure.
Author: Liz Davidson, Director of Clinical Services, LeadingAge Iowa
