WHCA/WiCAL staff met with DQA leadership on September 20^th  for a quarterly meeting. These important issues were discussed: 

• Survey Trends:
  • Elopement: Per DQA, this is a very recent trend. Surveyors are finding either that the resident has not been assessed for elopement risk or an elopement prevention plan has made created but not implemented, with an increase in elopements leading to injury;
  • Dietary: Surveyors are finding that facilities are either severely understaffed in this important area or the staff that is working is not properly trained;
  • Quality of Care: Specifically, incontinent residents are not being changed and/or turned frequently enough. Surveyors are seeing an increase in the number and severity of pressure injuries.

WHCA/WiCAL Staff Comment: We recognize that all of the above trends are being driven by the staffing shortage. The purpose of the above information is to provide you with an overview of what surveyors are seeing in the field.

• DQA’s recent announcement that they have contracted with HMS and LTCI for assistance in conducting recertification and complaint surveys:  HMS teams started in the field on September 16^th. The contract with LTCI was very recently signed so they are not in the field yet. The HMS and LTCI teams will work both independently and as part of DQA teams. The decision on which will depend upon the survey backlog and the availability of HMS and LTCI surveyors. Wisconsin is one of a collection of states (as well as CMS) that has contracted with one or both companies. DQA will be meeting with company representatives on a weekly basis to monitor progress.

Staff Comment: We recognize that DQA’s decision to contract out for survey services is a distressing one. Please know that WHCA/WiCAL staff is watching this issue closely.  Please let us know your experience, positive or negative, if you are surveyed by HMS or LTCI surveyors. Based on our research, the experience has been mixed across the country.

• Administrator and DON changes since 1/1/22:
  • Administrators: 262, including 104 temporary administrators;
  • DONs: 228. In some instances, DQA has noticed multiple turnovers within the nine months of data thus far in 2022. Clearly these high numbers are extremely troubling and lead to process/system breakdowns within a facility.

• Preparation for October 7^th sunset of Temporary and Emergency Nurse Aide Training waiver:

DQA reported generally sufficient access to nurse aide training and testing opportunities for students. The agency is addressing access issues as they arise. Headmaster, DQA’s testing partner, has done a very good job finding testing sites in fairly close proximity to where students are based. As such, the instance of the LaCrosse-based student having to travel to Milwaukee to be tested is currently rare and when it does occur, Headmaster works quickly to arrange a more geographically acceptable alternative. Regarding training, access in the Kenosha/Racine area continues to be challenging. DQA is working with Gateway Technical College and area facilities to make more training slots available. At this time, DQA will not be requesting a training or testing waiver from CMS for the October 7^th sunset date.

On a related issue, DQA reported that 114 facilities are currently under the two year prohibition to provide facility provided, on site nurse aide training programs. Facilities may request to have an on site program but it must be provided by a third party.

• Bivalent COVID-19 Boosters:

Do residents and staff eligible to receive the new bivalent booster need the booster to be considered “up-to-date” in their COVID-19 vaccine regiment? Answer: Yes. DQA recognized that this answer is causing some consternation and frustration in facilities. However, the agency and facilities are bound to follow the latest guidance from the CDC. Therefore, when a surveyor enters a facility, here is what they will be looking for:

• • Per F-tag 887: Were residents and staff who are eligible for the Bivalent vaccine offered it? If yes, and the facility has vaccine supply on hand, what is the process for administration? If the facility has no supply on hand, was it ordered?
  • For staff who would like the vaccine but have not yet received it, the facility should work with its medical director to determine what precautions should be taken to safeguard residents and staff until the vaccine can be administered.
  • F-tag 888 will still apply requiring a facility to track staff vaccine status for the bivalent vaccine.

Staff Comment: This information from DQA on the Bivalent vaccine appears to be contrary to the guidance that our national affiliate, the American Health Care Association/National Center for Assisted Living (AHCA/NCAL), has received from CMS. We will be following up with AHCA to obtain clarification. If we confirm that a discrepancy in interpretation does, indeed, exist, we will circle back with DQA to resolve the discrepancy.

Our September 20^th meeting with DQA was information-packed with several “gray” areas. WHCA/WiCAL staff is always available to assist you with any questions that you may have. Please do not hesitate to call on us: Jim Stoa, Vice President – Government Relations and Regulatory Affairs, jstoa@whcawical.org; Jena Jackson, Vice President – Quality Advancement and Education, jena@whcawical.org; Rick Abrams, CEO, rick@whcawical.org.