CHANGES TO FEDERAL REGULATIONSA Message from Anne Mason, QIDP
In case you haven’t heard, there are some new additions to Appendix J – Survey Procedures and Interpretive Guidelines for Intermediate Care Facilities in California for Persons with Intellectually Disabilities in the Code of Federal Regulations.
For years now, licensing has been trying to place the responsibilities of coordination and follow-up services on the QIDP. This has been an ongoing problem because all too frequently the facility owners, administrators, physicians, and even RNs do not include the QIDP. Without the areas of responsibility which fall under the QIDP being clearly defined, it becomes extremely difficult to implement the overall program in a structured manner.
There are also several sections addressing adequate staffing in the facilities. It is now written into the regulations that a QIDP be provided a sufficient number of hours per week, instead of just the minimum number of hours per client each week. Some facilities may need to get away from the idea of minimum required hours. Is your facility one of them? Is there enough staff on hand to take care of the client’s basic needs and still conduct each program adequately? If so, you’re fine. Naturally, this will depend on the number of individual clients in each house. Keep in mind that as the number of different behaviors and physically involved clients increase, so should the staff.
Other changes which affect those individuals who have been classified as “paperwork QIDP’s” is the amount of time required in the facility. Persons falling into this category will now have to give up their “extra” facilities and actually spend time in their facilities working with staff and schools/day programs. They will also need to read the entire chart and not just their section. There needs to be more involvement of consultants training the staff. I recommend all consultants have their in-service sheets signed by staff to confirm the number of hours worked.
I am willing to bet the surveyors have read this document and will be implementing the regulations at your next survey.
Be prepared and good luck!
Anne Mason, QIDP
Click the link below to download a copy of Appendix J of the Federal regulations:
Interpretive Guidelines for ICF for Persons with Intellectually Disabilities (W159-W180 (PDF) (Source: Code of Federal Regulations, Centers for Medicare and Medicaid Services, State Operations Manual - Appendix J, pages 77-87)