One regulation pending Phase 3 implementation is F-Tag 949 Behavioral Health Training. This regulation has significant connections to two other regulations for skilled nursing facilities: §483.70 Administration F-Tag 838 Facility Assessment (which should have been completed and submitted by November 2017) and §483.40 F-Tags 740-745 Behavioral Health Services.
As part of the facility assessment, skilled nursing facilities should have included in their plan a procedure to educate and provide competencies for behavioral health services through training of each staff member employed by the facility and contracted staff. These training segments must include, but not be limited to, treatment and services for mental and psychosocial issues, behavioral health as it relates to dementia care, a plan for assuring sufficient numbers of educated staff for residents with behavioral health needs and the plan to provide sufficient and medically based social services.
It is important for facilities to develop a comprehensive training plan that includes the following necessary training segments:
- Educate staff on the facility’s approach and policy on how to interact and treat residents who have a diagnosis of mental disorder or psychosocial adjustment difficulty or have a history of trauma or post-traumatic stress disorder (PTSD).
- Educate each member of the care team on how the policy of the facility approaches person centered care for individuals with behavioral health needs.
- Educate staff on those individuals who have no past diagnosis of behavioral health disorders, if they display facility adjustment issues after admission.
- Educate on staff documentation for individualized, person centered care approaches for residents with dementia related disorders.
As outlined in the “Guide to Surveyors” from the Centers for Medicare & Medicaid Services (CMS), “In phases one and two of implementation of the Reform of Requirements for Long-term Care Facilities, it is the expectation that all facility staff members, including non-nurse aide staff, assisting residents living with behavioral health needs, be competent in care areas. However, in phase three, under §483.95(i) (F949), Behavioral health, formalized training programs must be completed and documented for all staff that support and provide care for residents that have behavioral health needs.”
It is vital that formalized training plans for behavioral health services be developed prior to November 2019 inspections. Training plans should be level appropriate for each member of the facility, be recorded in each staff member’s training plan and be incorporated into the overall training plan of the facility. Documentation is key for any training segment within the facility, but a close look will be given to the behavioral training plan after November 2019.
If you need assistance with development of a training plan for behavioral health or any other segment of the regulations, please contact LW Consulting, Inc. for assistance.
LW Consulting, Inc. (LWCI) offers a comprehensive range of services that can assist your organization in maintaining compliance, identifying trends, providing education and training, or conducting documentation and coding audits. For more information, contact LWCI to connect with one of our experts!
