SURVEY AND REGULATORY UPDATE
ASSISTED LIVING INSPECTION PROCESS: THE EXIT CONFERENCE
Once the full survey is complete, DSHS licensors will hold an exit conference. This meeting may be onsite or via telephone, depending on various factors. There are several benefits of the exit conference, including:
  • Learn of deficiencies discovered during the inspection
  • Provide additional details should there be discrepancy in licensors’ findings and the facility’s practice
  • Ask clarifying questions

Before the exit conference convenes, the licensors must prepare by organizing the data gathered. They will conduct a private team meeting where they can discuss topics of concern based on observations, interviews, and record reviews. They will identify deficient practice and document their findings in an organized format using Attachment MThe most important/serious citations are documented at the top of the form, with less egregious next, followed by consultations/less concerning issues.

Licensors will work with the administrator to determine a time and location for the exit conference; ideally it is in a private location in the event confidential information is shared. Licensors will notify the ombuds of the time/date of the exit conference, in the event s/he wants to attend. Interested residents may also attend. The administrator generally invites all department heads/leadership to attend the meeting as well.

If residents and/or resident families are present during this meeting, licensors will not provide specific resident information in order to honor privacy.

Because the licensors have communicated with the administrator throughout the inspection, the identified deficient practice(s) presented during the exit conference should not be a surprise. The licensors may not have all the details during the conference in order to clearly identify whether an issue will rise to the level of a citation, particularly if the administrator or designee share additional information to clarify a topic of discussion; additional information may need to be gathered and/or they may need to discuss the issue with the field manager. If this is the case, they will discuss this during the meeting.

After the exit conference, the licensors will advise the administrator of general timelines to expect the written statement of deficiencies document delivery. They will share information on what to do with the document once it has been received, including signing, dating, and returning the cover page to DSHS to indicate receipt and signatures/dates indicating plan of correction timeframes. They will outline steps to take if facility administration disagrees with the findings in the document and desires an informal dispute resolution and, in the event of sanctions on the license, a formal administrative hearing.

The exit conference is an excellent time to take notes so staff can initiate plans of correction immediately; there is no need to await the formal Statement of Deficiencies document in order to begin process evaluation and systems improvement.

If you have questions about the inspection process in assisted living facilities, please contact Vicki McNealley via email, or call her at (800) 562-6170 extension 107.
SKILLED NURSING: RESIDENT-CENTERED CARE
Person-centered care remains a focus and priority of CMS and our state agency. CMS defines person-centered care in the Code of Federal Regulation (CFR) by stating, “person-centered care means to focus on the resident as the locus of control and support the resident in making their own choices and having control over their daily lives.” CMS further weaves this concept, expectation, and requirement throughout the Requirements of Participation.

By clearly stating that the resident is the locus of control, the requirements go on to emphasize the facility’s responsibility to “protect and promote” the rights of the resident, as well as stating that the resident’s wishes and preference MUST be considered in the exercise of rights by the resident’s representative.

Some key facility elements include, but are not limited to, the following:
  • The resident must be provided with opportunities to participate in the care planning process and informed in a language they understand of their right to participate in the development and implementation of the plan of care and in the development of goals and outcomes of care.
  • The resident has the right to be informed in advance of changes to the plan of care, to see the plan of care, and sign after significant changes.
  • The facility must facilitate inclusion of the resident and his/her representative in care planning and include an assessment of the resident’s strengths and needs.

While Washington State requires (WAC 388-97-1020) facilities to implement a plan of care to meet the immediate needs of newly-admitted residents prior to the completion of the comprehensive assessment and plan of care, additional expectations regarding new admissions are spelled out in F655, including the following:
  • The facility must develop and implement a baseline care plan for each resident that includes instructions needed to provide effective and person-centered care of the resident that meets professional standards of quality care.
  • The baseline care plan must be developed within 48 hours of the resident’s admission and include the minimum healthcare information necessary to properly care for the resident including, but not limited to initial goals based on admission orders, physician orders, dietary orders, therapy services, social services, and PASRR recommendation if applicable.
  • The facility may develop a comprehensive care plan in place of a baseline care plan if it is developed within 48 hours of the resident’s admission and meets the requirements.
  • The facility must provide the resident and their representative with a summary of the baseline care plan including any updated information based on the details of the comprehensive care plan.

These baseline care plan requirements are in addition to all of the resident-centered comprehensive care plan requirements outlined in F656 through F659. Keep in mind that the care plan must also be culturally competent, and trauma informed.

If you have questions or would like additional information about the skilled nursing survey process, please email Elena Madrid or call her at (800) 562-6170, extension 105.
303 Cleveland Avenue SE, Suite 206 | Tumwater, Washington 98501
Tel (800) 562-6170