W323 specifically deals with Vision and Hearing screenings. These screenings are required annually and to date have been completed by a variety of screeners. Audiologist, optometrist, and even physicians have completed these assessments to comply with the federal standards.
In Texas it has been generally accepted that if your physician checks hearing and vision and notes that it is "Okay" or "Within normal limits" etc, surveyors have stayed away from writing W323. Often this has been completed by simply a "check" next to "Hearing," and/or "Vision". These "checks" or "checkmarks" have been accepted in most survey regions of Texas for upward of twenty years now. That has recently changed apparently.
At a recent survey a surveyor noted that a "check" was not sufficient to indicate what sort of hearing and vision screening a physician had completed. It did not seem to matter that the choices for the check were "Normal," "Abnormal," and "Unable to determine". For the survey in question, "Normal" was checked for each individual questioned; however, that did not seem to meet the needs. The surveyor stated, "CMS has indicated that a checkmark is no longer acceptable and that we have to cite deficient practice for a checkmark." That statement was repeated again in the exit survey.
Interestingly, the standard did not change and neither did the information found in the federal tag regarding practices and probes. Apparently, someone working at CMS changed his or her opinion about what is and is not acceptable and issued some sort of memo to the states, or at least the state of Texas.
The particular facility in question had about five years worth of physicals on file at the home. I looked back through them and each had the same use of a "checkmark" for a review of vision and hearing. It appeared to support what I hear from many QIDP's and Administrators and that is that "Surveyors will find something no matter how good your program is doing." Ironically, none of the individuals with checkmarks have hearing devices or glasses. The individuals who have glasses in that home see an optometrist on a regular basis.
In the end the facility will have one of three choices. It can naturally appeal the decision of the surveyor in an attempt to find out if this was simple surveyor bias or if it has a foundation in the CMS oversight. The facility could simply start having everyone see an optometrist and audiologist regardless of needs and thus spend further Medicaid tax dollars. Finally, the facility could request additional information from the physician regarding specific test used to determine that everything "checks" out for an individual, and that could simply cause the physician to refer the individual to someone else. Whatever choice the facility makes, one thing is clear and that is that standards continue to be open to interruption whether its by an individual surveyor, a region, or even the federal government.
Monday, February 16, 2015
Sunday, February 1, 2015
Where does the QIDP Role Stop?
The QIDP is often given multiple task within the ICF/IID organization and the line between QIDP work and "Other" can sometimes become blurred together. The question then becomes "Where does the QIDP's role stop?" Most QIDP's reading this post will say it never stops, or it stops after I leave the organization. Sadly, this approach to QIDP work is making it harder and harder to find people willing to become QIDPs.
Consider the basic responsibilities of most QIDP's listed below:
1. Obtain Consents
2. Write CFA reports
3. Implement IPPs and Objectives
4. Maintain IPPs and Objectives
5. Coordinate services
6. Write Plans of Correction
7. Train Staff and monitor staff
8. Write Interim staffings between annual CFA meetings
9. Obtain and coordinate Specially Constituted Committee people, minutes and meetings
This short list is only the basic QIDP responsibility list. We could extend it further and likely give each item listed above sub-categories. Anyone looking at this would think initially, "That's not too much," and it might not be if a QIDP was assigned to only four to six individuals. However, the fact is most QIDP's have a caseload of somewhere between eighteen and twenty-four individuals. This means the QIDP has to do the above nine items for upward of twenty-four individuals.
This is twenty-four individuals with unique wants and needs, unique family dynamics, unique behaviors, and unique problems. Basically the QIDP is responsible for all nine areas presented and to be the counselor for the individual person.
This is where the lines often blur together and would-be QIDP's spend a brief amount of time working in the field before deciding that a teaching job or a job in a department store might present fewer headaches and fewer hours. When the line blurs together the QIDP might end up hiring new staff, training all the new staff, completing background checks on new staff, handling individuals money, accounting for property of the individuals, grocery shopping, shopping for clothing for the individual, minor repairs at the home, coordinating major repairs and on-and-on. The list of QIDP "Responsibilities" can rapidly grow to a point to where the QIDP is the Human Resource Manager, the Accountant, the Home Manager, the on-call staff person, etc. It can actually become overwhelming just to think about it.
All this being said though, the reader must still keep in mind that the caseload is the key to the QIDP's responsibilities. My QIDP (MY QIDP) started to meet the needs of small facilities. The fact is a six-bed facility owned by one person or even a small group, does not need a full-time QIDP. If they do have a full-time QIDP, there's a good chance that QIDP will have to have some other duties and responsibilities pertaining to the operation; however, the larger groups where a QIDP has a large caseload (18-24), you may want to consider giving a Home Manager responsibilities for home related items, a payroll or human resource department the responsibilities related to employees, and allow the QIDP to function as a QIDP and not the manager, book-keeper, director, staff training coordinator, etc. Once we reach a point where QIDP's can do the job they sought, we'll have happier QIDP's who decide to stay in the field rather than seek something different.
Consider the basic responsibilities of most QIDP's listed below:
1. Obtain Consents
2. Write CFA reports
3. Implement IPPs and Objectives
4. Maintain IPPs and Objectives
5. Coordinate services
6. Write Plans of Correction
7. Train Staff and monitor staff
8. Write Interim staffings between annual CFA meetings
9. Obtain and coordinate Specially Constituted Committee people, minutes and meetings
This short list is only the basic QIDP responsibility list. We could extend it further and likely give each item listed above sub-categories. Anyone looking at this would think initially, "That's not too much," and it might not be if a QIDP was assigned to only four to six individuals. However, the fact is most QIDP's have a caseload of somewhere between eighteen and twenty-four individuals. This means the QIDP has to do the above nine items for upward of twenty-four individuals.
This is twenty-four individuals with unique wants and needs, unique family dynamics, unique behaviors, and unique problems. Basically the QIDP is responsible for all nine areas presented and to be the counselor for the individual person.
This is where the lines often blur together and would-be QIDP's spend a brief amount of time working in the field before deciding that a teaching job or a job in a department store might present fewer headaches and fewer hours. When the line blurs together the QIDP might end up hiring new staff, training all the new staff, completing background checks on new staff, handling individuals money, accounting for property of the individuals, grocery shopping, shopping for clothing for the individual, minor repairs at the home, coordinating major repairs and on-and-on. The list of QIDP "Responsibilities" can rapidly grow to a point to where the QIDP is the Human Resource Manager, the Accountant, the Home Manager, the on-call staff person, etc. It can actually become overwhelming just to think about it.
All this being said though, the reader must still keep in mind that the caseload is the key to the QIDP's responsibilities. My QIDP (MY QIDP) started to meet the needs of small facilities. The fact is a six-bed facility owned by one person or even a small group, does not need a full-time QIDP. If they do have a full-time QIDP, there's a good chance that QIDP will have to have some other duties and responsibilities pertaining to the operation; however, the larger groups where a QIDP has a large caseload (18-24), you may want to consider giving a Home Manager responsibilities for home related items, a payroll or human resource department the responsibilities related to employees, and allow the QIDP to function as a QIDP and not the manager, book-keeper, director, staff training coordinator, etc. Once we reach a point where QIDP's can do the job they sought, we'll have happier QIDP's who decide to stay in the field rather than seek something different.
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