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Phase Three of Requirements of Participation

Posted Apr 1, 20193 min Read

Regulatory & Clinical
  1. Freedom from Abuse, Neglect, Mistreatment, and Exploitation
  2. Trauma-Informed Care and Behavioral Health Services;
  3. Food and Nutritional Services;
  4. Infection Control/Infection Preventionist Program; and
  5. Quality Assurance/Performance Improvement

What is Trauma-Informed Care?

Many people seeking care in nursing homes have many different types of trauma in their lives and becoming “trauma-informed” means recognizing it and implementing compassionate care and services appropriately.  Those with trauma need support and understanding from those that care for them in order to prevent re-traumatizing them by caregivers and service providers.  Understanding the profound impact of any type of trauma is important in providing person-centered care.

As care providers, we must see Trauma-Informed Care as an organizational structure that includes understanding, recognizing and responding to all types of trauma.  The approach to providing Trauma-Informed Care must include emotional, psychosocial and the physical well-being of our seniors, their support persons and our caregivers.

F699 §483.25(m) will be implemented beginning November 28, 2019 during phase 3 of the requirements of participation.   Trauma-Informed care understands and considers the pervasive nature of trauma and promotes environments of healing and recovery rather than practices and services that may inadvertently re-traumatize.

Intent of §483.40(b) & §483.40(b)(1)

  • Upon admission, residents assessed or diagnosed with a mental or psychosocial adjustment difficulty or a history of trauma and/or post-traumatic stress disorder (PTSD), receive the appropriate treatment and services to correct the initial assessed problem or to attain the highest practicable mental and psychosocial well-being
  • Residents who were admitted to the nursing home with a mental or psychosocial adjustment difficulty or have a history of trauma and/or PTSD, must receive appropriate person, centered and individualized treatment and services to meet their assessed needs.

IHCA continues to offer education to help prepare our members for the phase III requirements, however there are actions you can take now toward compliance.

Recommended Actions to begin implementation:

  1. Provide staff information including copies of the Federal regulations for Trauma-Informed care and Behavioral Health Services.
  2. Create a working committee to complete the following:
  • Review and revise policy and procedures
  • Review and revise the Facility Assessment
  • Train staff and validate competency
  • Ensure contractual agreements of partners needed to provide services for your resident population as identified in your Facility Assessment.

There are many integrated and overlapping of the regulatory standards and the following must be considered as providers implement Trauma-Informed Care and Behavioral Health Services RoPs:

  • Bed Rails – Potential for trauma
  • Restraints and Involuntary Seclusion
  • Unnecessary medications
  • Abuse and neglect
  • Pre-admissions screening and resident review (PASARR)
  • Admission assessments
  • Informed Consent
  • Determination of resident capacity
  • Sufficient staff
  • Skill and competency of staff

Contact ldavenport@ihca.rg if you have questions or need assistance.