Hospitals: Get Ready for 2019 CMS CoP Standards

Do you know what 2019 has in store for hospital Conditions of Participation (CoP) standards? Hint: A lot! There are numerous changes on the horizon—especially those that will impact your nursing services.

Centers for Medicare & Medicaid Services (CMS) deficiency reports have cited Nursing Services CoPs more than 4,740 times in the recent past, says hospital compliance expert Sue Dill Calloway in her ProfEdOnDemand CMS CoP Standards 2019 webinar. That’s led to increased agency scrutiny of CoP compliance. Plus, CMS has is revising the Nursing Services section for 2019. All this means you have a whole new level of complexity in your nurse-staffing practices.

What the CoPs Currently Say About Staffing

Background: The hospital CoPs section on Nursing Services (§ 482.23) requires that hospitals have organized, 24-hour nursing services, furnished or supervised by a registered nurse (RN).

There are three major standards for the Nursing Services CoPs:

  1. Organization: Your hospital must have a well-organized service with a plan of administrative authority and delineation of responsibilities for patient care. The director of the nursing service must be a licensed RN and is responsible for the service’s operation, including determining the types and numbers of nursing personnel and staff necessary to provide nursing care for all areas of the hospital.
  2. Staffing and Delivery of Care: Your hospital’s nursing service must have adequate numbers of licensed RNs, licensed practical (vocational) nurses, and other personnel to provide nursing care to all patients as needed. You must have supervisory and staff personnel for each department or nursing unit to ensure, when needed, the immediate availability of a RN for bedside care of any patient.
  3. Preparation and Administration of Drugs: Your hospital must prepare and administer drugs and biologicals in accordance with federal and state laws, the practitioner’s orders, and accepted standards of practice.

Problem: Unfortunately, the CoPs are rather vague when it comes to nurse staffing ratios. They simply state that hospitals must have “adequate numbers” of licensed RNs, licensed practical (vocational) nurses, and other personnel. This nebulous language has caused states to take action to ensure optimal nurse staffing, according to the American Nurses Association.

State nurse-staffing laws tend to follow one of three general approaches:

  • Require hospitals to have a nurse-driven staffing committee that creates staffing plans to reflect the patient population’s needs and match the staff’s skills and experience;
  • Mandate specific nurse-to-patient ratios in legislation or regulation; or
  • Require facilities to disclose staffing levels to the public and/or a regulatory body.

Consider These Staffing Factors

Maintaining the appropriate number and mix of nursing staff is critical to delivering quality patient care in a hospital, stressed Lippincott Solutions. “Numerous studies reveal an association between higher levels of experienced RN staffing and lower rates of adverse patient outcomes.”

Benefits: Adequate nurse staffing helps to reduce medical and medication errors, patient mortality, hospital readmissions, length of stay, preventable events such as patient falls and infections, and patient care costs. But your staff benefits too: Sufficient nurse staffing can prevent job dissatisfaction, fatigue, and burnout among employees.

How to determine appropriate nurse-staffing levels? A wide variety of factors influence a hospital’s nurse-staffing needs, such as:

  • Intensity of patient needs
  • Patient complexity, acuity, or stability
  • Number of admissions
  • Discharges and transfers during a shift
  • Nursing staff’s level of experience and skill level
  • Physical space and layout of the unit
  • Availability of or proximity to technological support or other resources

Stay Current on CoP Changes

Some stakeholders believe that establishing mandatory nurse-to-patient ratios under federal law would help improve patient care overall. Others favor more flexible staffing guidelines that allow nurses to create staffing plans specific to each unit in their hospitals, combined with establishing minimum upwardly adjustable staffing levels.

Bottom line: Don’t let the Nursing Services CoP standards become a survey sore-spot for your hospital, warns Sue Dill Calloway in her webinar, “Nursing: CMS CoP Standards for Hospitals and Proposed Changes 2019 Update.” Make sure your hospital is complying with the current standards—and keep your eyes peeled for the 2019 nursing changes, so you can operate compliantly and protect your Medicare reimbursement.

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