To accomplish the goal of minimizing staffing, multiple provider agencies have heard from case managers and insurance adjusters who refer to this aspect of State of Michigan Licensing Rules:
R 400.14206 Staffing requirements.
Rule 206. (1) The ratio of direct care staff to residents shall be adequate as determined by the department, to carry out the responsibilities defined in the act and in these rules and shall not be less than 1 direct care staff to 12 residents and children who are under the age of 12 years.
(2) A licensee shall have sufficient direct care staff on duty at all times for the supervision, personal care, and protection of residents and to provide the services specified in the resident’s resident care agreement and assessment plan.
The Michigan Department of Licensing & Regulatory Affairs, Bureau of Health Systems warns against a misrepresentation, especially when it can be a factor in contributing to potential harm of a resident as recommended and tolerated by licensed healthcare professionals. This typically occurs when associated with an effort to reduce the cost of care, which a provider does not have the luxury to consider when ensuring a resident’s needs are met.
While the staffing ratio can be 1 to 12 or 1 to 6 as a minimum or baseline, the same rule continues with: (2) A licensee shall have sufficient direct care staff on duty at all times for the supervision, personal care, and protection of residents and to provide the services specified in the resident’s resident care agreement and assessment plan.
A breakdown of what the staffing requirements refer to in terms of resident need:
Supervision:
- Fall Prevention
- Behavioral Management
- Bed safety
- Turning for those with mobility limitations
Personal Care:
- Incontinence management
- Wound prevention
- Wound treatment
- Infection prevention
- Special feeding assistance
- Trach maintenance
Protection:
- Movement to prevent and manage existing wounds
- Response to untoward behaviors of the resident or other residents
- Immediate and safe removal in the event of a fire or other emergency
Special Staffing Arrangements in Adult Foster Care: Ensuring Resident Safety and Care…
The care and safety of residents in adult foster care often necessitate special staffing arrangements tailored to the unique needs of each individual. This approach is akin to the model employed by nursing homes and hospitals, where auxiliary services are billed separately to accommodate specific care requirements. In adult foster care, the level of supervision, personal care, and protection varies significantly from one resident to another. Licensing rules expect care homes to adapt and pivot in response to these individual concerns, ensuring that each resident receives appropriate and personalized care. A cookie-cutter approach to save money is unethical.
Understanding Licensing Rules and Their Impact:
Licensing rules in adult foster care are designed to ensure that homes provide individualized care tailored to the specific needs of each resident. These rules mandate that facilities must be flexible and responsive to changing care requirements. When medical professionals misinterpret these rules, leading to a reduction in necessary services, it can have serious implications for the safety and well-being of residents. Providers rely on a business model that incorporates the provision of essential services, and any reduction in these services can compromise the care of vulnerable residents.
The Role of Medical Professionals and Regulatory Scrutiny:
Medical professionals play a crucial role in interpreting and implementing care regulations. However, when they align with a misinterpretation of these rules, it can result in reduced services that are vital for the resident’s safety and well-being. This misalignment can position these professionals, especially guardians, for regulatory scrutiny. Regulatory bodies expect that the care provided meets the established standards and addresses the medical needs of the residents. Ignoring these needs not only jeopardizes resident safety but also brings the professionals involved under closer inspection by regulatory authorities
Addressing Complex Medical Needs:
Residents in adult foster care often have complex medical needs that require special attention. Wound prevention, for example, is a critical aspect of care for many residents. Ensuring that wounds do not develop or worsen requires diligent monitoring and specialized care. In the event of an emergency, such as a fire or natural disaster, evacuation plans must account for residents who need extra help. These scenarios highlight the importance of having dedicated staff members who are trained and prepared to address these intricate needs promptly and effectively.
The Fluidity of Human Needs:
Human needs are fluid, and medical circumstances can change rapidly, especially in older adults. Chronic conditions may worsen over time, necessitating adjustments in care plans and staffing arrangements. A resident who was previously stable may suddenly require more intensive care due to the progression of a condition or the onset of a new medical issue. This dynamic nature of care needs underscores the importance of having flexible and responsive staffing arrangements in place.
The Importance of Attendant Care:
Attendant Care is often a separate and crucial charge in the care model of adult foster homes. This service provides a dedicated attendant for a resident, ensuring that their specific needs are met without relying solely on the general supervision of the foster home team. Having a dedicated attendant mitigates the risk of ethical and safety dilemmas that can arise when the general staff is stretched thin or unable to provide the necessary level of care. It ensures that residents receive the personalized attention they require, enhancing their safety and overall well-being.
Ethical and Safety Considerations:
The ethical and safety implications of inadequate staffing and care cannot be overstated. When residents do not receive the level of care they need, it can lead to deteriorating health conditions, increased risk of injury, and a decline in overall quality of life. For the management of a foster care facility, ensuring that each resident receives appropriate and adequate care is not only a regulatory requirement but also a moral obligation. Failure to meet these standards can result in severe consequences, both for the residents and the facility.
Care First Rehabilitation is steadfast in its commitment to providing high-quality care that meets or exceeds the standards set by licensing authorities. The organization will not risk its standing in the long-term care community nor the credentials of its skilled personnel by misinterpreting licensing rules or agreeing to sub-standard care arrangements to satisfy the cost-saving goals of an insurer. Adhering to the highest standards of care is non-negotiable for Care First Rehabilitation, as it ensures the safety, dignity, and well-being of those in their care.
We would hope that physicians and case managers share this dedication to maintaining their professional standing and credentials. Compromising on care to meet financial constraints not only jeopardizes patient outcomes but also risks attracting regulatory scrutiny. It is essential that all parties involved in the care continuum prioritize the health and safety of patients above cost considerations, ensuring that care decisions are driven by medical necessity and best practices rather than financial incentives.
To summarize:
The care and safety of residents in adult foster care require special staffing arrangements that are responsive to individual needs. Licensing rules mandate that facilities must be flexible and adaptable, providing personalized care that addresses the unique requirements of each resident. Medical professionals must interpret these rules correctly to ensure that services are not reduced inappropriately, thereby safeguarding the well-being of residents. Attendant Care is a critical component of this care model, providing dedicated support and mitigating ethical and safety concerns. By maintaining appropriate staffing levels and specialized care arrangements, adult foster care facilities can ensure the safety, health, and dignity of their residents. You will not find one daily rate in a hospital or nursing home and the same cannot be expected in community based settings.
Hospitals and nursing homes typically bill Medicare and other insurers a daily rate for room and bed occupancy, known as the “per diem” rate. This rate covers the basic costs associated with a resident’s stay, including accommodation, meals, and basic utilities. However, services that require additional labor or specialized care, such as nursing care, sitters, and various therapies (physical, occupational, and speech therapy), are billed separately. These services are considered ancillary or non-routine and are itemized on a resident’s bill, reflecting the additional resources required to provide them. According to Medicare policy, under the Prospective Payment System (PPS) for skilled nursing facilities (SNFs), the per diem rate is determined by the Resource Utilization Groups (RUGs) classification, which considers the intensity of services provided to the patient. However, Medicare Part A covers these services as part of the bundled payment for inpatient stays, meaning that while the room and board are covered under the per diem, additional services are reimbursed separately if they meet specific criteria for medical necessity. Medicare Part B may also cover outpatient services such as therapies when they are medically necessary and properly documented. This separation of costs ensures that the facility is reimbursed fairly for the various levels of care provided, aligning payments with the specific needs and intensity of services required by each patient.
Another Blog Post by Direct Care Training & Resource Center, Inc. Photos used are designed to complement the written content. They do not imply a relationship with or endorsement by any individual nor entity and may belong to their respective copyright holders.
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