From OIG Guidance To Actionable Dashboards For Resident Safety

We trace how OIG’s guidance elevates patient safety and quality from ideals to daily compliance work, and share lessons from Corporate Integrity Agreements that separate paper programs from living systems. Practical tools, clear dashboards, and a culture of “why” turn metrics into safer resident care.

• OIG focus on quality and patient safety as compliance outcomes
• Building a facility framework with clear indicators and thresholds
• Using dashboards to measure, share, and act on trends
• False claims risk tied to substandard care and billing
• Lessons from external monitoring and CIAs
• Culture of inquiry at board and frontline levels
• Resources from CMS, AHRQ, and NIH for frameworks
• Root cause analysis for falls and adverse events
• Competency alignment with acuity and specialized units
• Walking rounds for real-world validation of safe practice

Please feel free to reach out to Verity Consulting at VerityTeam.com if you'd like further assistance with your healthcare compliance needs

Chapters

• 0:00 Welcome And Scope
• 0:59 OIG’s Patient Safety Emphasis
• 3:12 Frameworks And Dashboards That Work
• 6:22 False Claims Risk From Substandard Care
• 6:58 Lessons From Corporate Integrity Agreements
• 10:28 Culture Of Inquiry And Board Engagement
• 12:07 Tools From CMS, AHRQ, And NIH
• 15:05 Root Cause Analysis And Data Use
• 16:53 Walking Rounds And Competency Checks
• 18:15 Summary, Rights, And How To Get Help
• 19:58 Closing And Contact Info

Transcript

SPEAKER_01: 0:15

Hello, I will be your host. My name is Deanna Five. I am a registered nurse and healthcare analyst. Let's get started.

SPEAKER_00: 0:27

The views or opinions expressed in his podcast are for informational purposes only, not intended as legal or professional advice, and may not represent those of Verity Consulting. Although we make strong efforts to make sure our information is current, at the time the podcast episode was recorded, Verity Consulting cannot guarantee that all information in this podcast is always complete. All information in this podcast is subject to change without further notice.

SPEAKER_01: 0:54

Welcome to Vital Compliance Insights. I'm your host, Deanna Phi. Today I want to talk about OIG's focus on the patient, resident safety, and quality concerns that they've outlined. And let me just kind of go over where I want to go with that. I want to just talk about what they're saying in that regard. And I also want to talk a little bit about my experience as an external monitor working with the OIG to conduct corporate integrity agreements. And I have some discussion there about really what does that mean and how does that look, certainly during a monitoring experience for a facility. I do want to talk about the importance for facilities to build a framework, a sound framework that identifies the resident quality and safety focus. So you have to have a framework and a system that's built to support that. A reproducible, consistent, consistently implemented process so everybody knows what are the quality indicators, what are the safety indicators to benefit the residents. And certainly, you know, you never want to run into situations where the OIG has concerns about substandard care, and then ultimately that could lead to false claims. So I'll talk a little bit about dashboards, why dashboards are important and helpful for an organization, and I'll just touch upon some of the resources that are out there for facilities to reach out to, to develop meaningful dashboards systems to measure, monitor, track, and then take some action to address any areas that are falling out of the expected goals and outcomes. So with that, I'm going to get started. And I'll try to keep this fairly moving fairly quickly here. So just to give us a little historical view here, OIG published the November 2023 General Compliance Program Guidance. And in that document, you really need to read that. So that particularly I'm focusing on page, I think it's page 60, nope, it's page 76 of the document. And the title of that is Quality and Patient Safety. And the OIG has long been focusing on this, as has CMS, but they're really saying here that they're looking to find out do you have a means by which you can monitor quality, monitor it, track it, conduct investigations into any deviation from what the standards of care are, and using that dashboard, that methodology to share with key stakeholders, to particularly staff. How are we doing? Are we doing a good job? We have had problems with Resident Falls. What's the benchmark? Are we better? Are we not better? Why? So it really is meaningful to have that information, just much like our checkbooks. We want to know what's there, what should it be, and where do we want it to be. So it helps us to have some gauge of some sort. There are many toolkits out there. There's information for boards, the facility board, the corporate boards, to have an understanding about quality and patient safety, what it means and what it should look like, and means to track and measure it. So with that said, there needs to be a framework built that the compliance committee, compliance officer, has developed with the board, with the leadership, and get information from key stakeholders to find out what are some of the indicators that we want to measure. Now, the C CMS, Centers for Medicare, Medicaid Services, they have some tools out there to help measure patient resident safety, quality, safety, and quality of care. So this is something that OIG has put in their own publication for guidance to say this is a focus for us as well. It always has been, but we really want to push for people to understand how significant this is. And I already mentioned it very quickly, but certainly false claims can occur. And what I mean by that is the facility provided substandard care. And as a result, build, build for that care. And that would be a false claim, or could be end up being a false claim. And that's when the OIG is going to certainly want to pay attention to patterns and occurrences where there's some systematic failures. And so, in my experience as an external monitor, I conducted corporate integrity agreement monitoring on behalf of the OIG as an external monitor. And in that work, I worked with numerous organizations across the United States. I will tell you that one stands out, one corporation organization. They were on the ball. They put together some wonderful quality measurement tools and they they lived, they breathed them. It wasn't just the compliance officer and the board maybe looking at this. Really the whole organization. They freely shared information on how they were doing and where they could get better and what their action was to move in that direction of improvement. So I was really impressed with that particular organization. In fact, they did end their corporate integrity agreement with the court with the OIG sooner than anticipated, and to their credit and certainly to the OIG's, I'm sure, relief. Then I will say I worked on the other end of the spectrum where I worked with organizations that, well, they just didn't quite get it. And what I mean by that is I guess to me it's a central value that I'm a nurse now, just to give you that background. Again, I'm a nurse, and I want to know that quality resident care is being provided. It's an expectation, it's a right. And so I want to know if that's not happening. And certainly for my loved ones, for my residents, my patients, what are we not getting right? So that is an important component of just my professional practice. But not everybody has a good understanding of what it means to have quality of care and safety. And the quality of care, they're based on standards, evidence-based practice standards. So this is a foundation that OIG, CMS, really all health care agencies agree on. And I think that's what everybody wants. And I will say that there were some organizations that clearly, well, let's just say they obfuscated frequently, very vague, unclear on what their framework was, what their system was to monitor. So it was always kind of a moving target, and it was very difficult because ultimately the residents were the ones that were at the short end of the stick in terms of not having a nursing facility dedicated to learning how to develop systems to monitor, to assess for risks, and to identify what those thresholds, those standards should be to measure compliance, and people being comfortable asking why. In fact, I've seen some dashboards that were developed where, let's say, the facility was tracking falls, resident falls with major injury. Let's just kind of isolate it there. And they were tracking this information, they assigned a threshold. And but what really struck me was when this information was presented to a compliance group or a board, if I was listening to a board meeting, there was very little discussion about, well, why is that? How are we doing? Are we moving the football down the field, so to speak? What are some of the barriers? You really didn't hear that discussion. And certainly I'm not naive. You know, I'm the monitor listening to this discussion, but it nonetheless was disconcerting that, disconcerting that people weren't comfortable just asking, can you elaborate on that a little bit more? Or can we have another discussion about that? So very, very concerned. There needs to be a culture within an organization that's comfortable asking questions and saying, I want to learn a little bit more about that. So we know OIG has made it very clear that they are taking this very seriously, patient safety, quality of care. And certainly they are saying, look, there can be false claims. And you know, when you get into that, that's a whole nother ball game. So I'm asking nursing facilities to just really say, I don't know what to do, I don't know where to turn, and to be comfortable reaching out. The CMS offers resources for nursing facilities to measure patient resident safety and quality of care. Some of you may be familiar with the Agency for Healthcare Research and Quality.gov. That agency provides rather a great deal of information, resources. And for an example, I'll just talk to you a little bit about that. When when AHRQ is putting together some guidance here, they actually go as far as helping a facility develop a framework. So here I'll just go over some of the six elements that they indicate that are essential. So the elements in this framework would include safety. We want to avoid harm. Another element has to be effective based on scientific knowledge. The framework should be patient resident-centered, and that should be respectful and value the person, persons. It should be timely, and it should be something where there's you avoid delays in harm by inaction. It should be efficacious, avoiding waste, whatever the resources are or the whatever resources they may be. And another element would be equitable. There should be no variation in quality. There shouldn't you should remove ethnic bias and those kinds of things. So there are resources out there to help people to develop a framework by which you can develop metrics and measurement methodologies for an organization to make sure you're on track. So NIH is another place where you can turn for resources and learning, additional learning. The National Institute of Health defines patient safety and quality as a focus on outcomes. Okay, what are the outcomes? Well, we do know, to use that example about residents falling, major injuries, well, we do know people, residents will fall at times. We do understand that. And the expectation here is to ask, how can we, if how can we mitigate that? How can we avoid that? And if it does occur, to go back and do a root cause analysis and say, what happened here? What happened with, I use myself as the example, Deanna. Deanna's had three major falls in the last three months. What's going on? Now you don't want to wait for three major falls to ask these questions, but certainly it would beg the question of what's going on with this resident. So we do want uh individuals to use some of the quality standards that are out there to ask some of these root cause analysis questions. In my work as an external monitor, a great deal of the work that we provided for facilities needing some guidance on how to avoid poor outcomes, negative outcomes, was to help them to do relevant data-driven information collection that then we could apply evidence-based standards of practice information to on what should we expect, what should be the standard, and then collect that data, analyze that data, and teach and help people to learn about root cause analysis. How, what happened here? How can we learn from this? So I do recognize this as a nurse. It's inherent in my practice, that's just part of my educational background. Now, patient safety and quality of care has always been part of my training and education, but not everybody has that same information, same understanding. So it's really important for the compliance officer, the compliance committee to articulate and assess people's levels of understanding of what it means to be safe. I've actually talked to nursing assistants who said, well, people fall. They're gonna fall. So some folks, they just need some more education and understanding, but find out where they are in their understanding so that you can do some targeted perhaps education. Because the goal here is for patient safety to develop systems that are gonna prevent adverse outcomes, errors, serious injury, and death. So we want we want to make sure a nursing facility develops a framework to measure, monitor, to put into place some measurement tools, okay? And then we want to make sure we encourage an environment that's dedicated to high quality of care standards and a culture of safety, and that our practices will, when you're observing me, when I don't know you're watching me, you are observing me to have safe practices. Okay. So I've done a great deal of work as a monitor looking at some outcomes, outcome data. And I know I've brought this up in prior episodes, but this is perfect time for the compliance officer, depending on whatever the compliance officer's educational background may be, to get out, walk around, look and talk to people, ask questions, listen to what people are saying. And the compliance committee hopefully is made up of a diverse group of people with different backgrounds that will also conduct some walking around rounds in a facility to find out: are we living a culture of safe practices to protect our residents? And are we providing the highest quality of care? Okay. So just to summarize here, it's important for a facility to build a framework in their facility that is going to be dedicated to a culture of safety and high quality of care. And with that follows a risk assessment to determine where our risks are, what are our outcomes, how are we doing, develop thresholds to measure and to measure progress to see if we're moving in the right direction. Okay. Conduct some education, some training, and that training and education should be based upon evidence-based practices. Make sure those policies and those procedures are in place and readily and easily available. Okay? But I always say this: go out and find out if people understand it, because putting it out there and talking about it might not translate to, I got it. And each discipline in the organization has a role to follow the accepted standards of practice. For example, I was in a facility where they had a ventilator care unit in this nursing facility. And certainly the first question I'm going to ask is: are there competencies based on this resident population's care needs, unique care needs? Okay. So the LIG recognizes there are standards of care, and those are central to quality of care. They do recognize that there are different settings. Hospitals have different standards, perhaps, than nursing facilities. But I'll say with caution, I've been in multiple nursing facilities where there's some high-level acuity of care that the residents are receiving. So just really take a look at that when you're developing your quality of care indicators and safety parameters. So I want to make sure I touched on this. I'm really excited to be honest with you that OIG is really focusing on this. And you know, it does certainly translate to, well, it can rather, excuse me, translate to false claims. And there needs to be a framework, a system developed. There needs to be ongoing monitoring and tracking to see are we are we on track with what our goals are for patient quality and safety. It's resident's right. And so I think we all agree on that. Well, I hope this episode was helpful. It was a quick overview. And if you have any questions, please don't hesitate to reach out to VerityTeam.com. Thank you. Thank you for listening. Your time is appreciated. We hope you enjoyed this episode of Vital Compliance Insights and found this to be informative. Please feel free to reach out to Verity Consulting at VerityTeam.com if you'd like further assistance with your healthcare compliance needs. Stay tuned for the next episode.