Long-Term Care Survey Alert

7 ways to keep a step ahead of the latest evidence-based practices.

You want to do nursing procedures "by the book," so to speak, if you don't want surveyors to throw the book at your facility.

The following strategies will help ensure your facility develops nursing policies and procedures that surveyors and plaintiff attorneys can't use as fodder for F tags and lawsuits.

1. Avoid a "cut and paste" approach to developing manuals. You don't want to just copy nursing policies and procedures from a form book, warns Joseph Bianculli, an attorney in private practice in Arlington, VA. Instead, think through whether the p/p meet the accepted standard of care in your setting, he advises.

Avoid this: One newly hired DON tells Eli that her nursing home administrator told her to simply use the nursing policies and procedures she'd  developed for her previous hospital employer. But that approach will set you up for survey problems because "the standard of care for a hospital will be different than the one in long-term care," observes Nancy Shellhorse, an attorney with Thompson & Knight, LLP in Austin, TX. "The standard in a nursing facility may be higher, as it is for pressure ulcers," she says. "A subacute  nursing facility would be held to a different standard than a chronic-care facility."

Real-world solution: One facility consulted with geriatric nurse practitioners to identify a nursing textbook and other resources best suited to its care population. The nursing administration staff then used the resources to supplement a nursing procedure manual. Each nursing procedure in the policy/procedure manual provided some basic "how to" information and referred the reader to designated pages in the nursing texts marked with color-coded tabs. The facility maintained copies of the nursing textbooks chained to the nursing station desk and in the medication room.

2. Don't let consultants lead you astray. If you use consultants to help you develop manuals, make sure they know long-term care and geriatrics, advises Shellhorse. "The consultant told me to do it" won't fly with surveyors asking you to explain why a faulty nursing procedure caused a negative outcome.

3. Incorporate manufacturers' instructions for use (IFUs) in your policies/procedures. Using an IFU helps the facility reduce its liability if a resident suffers an adverse event from a product or procedure, says Kathleen Thimsen, RN, ET, MSN, president of RARE Consulting Inc. in Bella Vista, AR. 

Beware of "off label" use of a wound-care product or device, Thimsen cautions. The physician and facility administrator should decide--in consultation with the manufacturer--when to develop p/p allowing staff to use a product for a purpose other than what the Food and Drug Administration has approved, Thimsen says.

Tip: Some vendors will supply cute laminated cards and charts spelling out how use a device, such as a glucometer, correctly. Post those in the medication room and on medication and treatment carts.

4. Tap the expertise of your respiratory care providers and pharmacy. Encore Healthcare works with its medical vendors to develop best practice policies and procedures for ventilator and respiratory care, IVs and total parenteral nutrition (TPN).

"We use a respiratory therapy company that helps us obtain evidence-based practices for our ventilator unit," says Susan Davis, MS, RN, VP of clinical operations for the Columbia, MD-based nursing facility chain. "And we use our pharmacy vendor to do the same related to TPN and IV therapy."

5. Keep non-nursing disciplines in the loop for more complex skilled nursing procedures. For example, when providing ventilator services, you need multiple p/p to address each discipline and aspect of care, including nursing, medical, respiratory therapy and ventilator operation, advises Grace Barbiere, RN, director of nursing services for Dr. William O. Benenson Rehab Pavilion in Flushing, NY, which has a ventilator unit.

6. Update your policies and procedures on a regular basis. Encore Healthcare reviews its policies with its vendors' input at least annually to see if they need updating, says Davis.

Tip: Give staff nurses Internet access at work to search for updates on the best way to do a nursing procedure or a care practice, suggests Diana Waugh, BSN, RN, principal of Waugh Consulting in Waterville, OH. The nurses can then share what they find out with the care team.

7. Educate, educate, educate. No policy/procedure will help guide care if the staff doesn't read it, says Clare Hendrick, RN, a geriatric nurse practitioner and consultant in San Clemente, CA. "Training according to the information in the manuals is what it's all about."