There are dozens of questions surrounding Behavioral Health F Tags so we sat down with Teresa Remy, Director of Consulting at LeaderStat, to get her thoughts.
1. What F Tags are included in this new Requirement of Participation (RoP) for Behavioral Health Services?
The Behavioral Health Services CFR includes: F Tag # F 740 Behavioral Health Services, F Tag # 741 Sufficient/Competent staff-Behavioral Health Needs, F Tag #742 Treatment/Services for mental/Psychosocial Concerns, F Tag # 743 No Pattern of Behavioral Difficulties unless avoidable, F Tag # 744 Treatment/Services for Dementia, F Tag # 745 Medically Related Social Services.
2. Are surveyors able to give Substandard Quality of Care (SQC) designation if a F Tag deficiency is issued under Behavioral Health Services?
Yes! Keep in mind a couple of things. First, consideration is which Behavioral Health Services F Tags are designated by CMS to be considered for SQC if there are deficiencies found under this RoP (F Tag # 742-745). Secondly, the definition of SQC which would be if the deficiency has a severity/scope level of F, H, I, J, K or L. Surveyors are issuing deficiencies for these tags and issuing SQC for many of these tags. This is expected to increase in RoP Phase 3.
3. The new RoP discusses Trauma Care. Is that also included in the new RoP F Tags for Behavioral Health Services?
Yes. Under the CFR for Quality of Care there is a new F Tag # 699-Trauma Informed Care, which is effective in RoP Phase 3. Keep in mind there are sections of the Behavioral Health F Tags that also include Trauma Care ( F Tag # 741-743). In RoP Phase 3, it includes these F tags along with F Tag # 949 Behavioral Health Training. Therefore your Behavioral Health Program must meet all of these new requirements with RoP Phase 3 (November 28, 2019).
4. Who in the SNF will play a role in the success of “kick starting” our Behavioral Health Program?
It is a crucial to have the right team selected to establish, train and implement the steps in your Behavioral Health Program. This will need to be a team effort. All disciplines that contribute to the care of residents/services should be involved. This may include the Administrator, Social Services, Activities, MDS, nurses, Nursing Assistants, physicians, therapists, health information management, etc. Keep in mind an effective Behavioral Health Services Program would be measured by all staff working together towards meeting the Behavioral Health needs of the residents. In addition, documentation must reflect this as well.
5. Will further training be necessary?
Definitely! These Behavioral Health RoP are new for everyone. Some of these new Behavioral F Tags never had an “old F Tag” in the previous RoP. These F Tags each have a regulation that are not only new but the interpretative guidelines are also new. Keep in mind many staff have never had behavioral health training, or haven't had training since the implementation of the new RoP phases 1, 2 and soon to be 3.
6. In the new RoP there are so many pages under Behavioral Health Services which contains new language. Where do I start?
You are not alone. It can be extremely overwhelming when you read the new RoP related to Behavioral Health Services. I recommend thinking about the first 3 steps needed then once that's completed do the next three steps. LeaderStat has designed a training plan and tools that can be implemented to get your behavior health services program off the ground. These tools are simple and easy to use in the “ real world”.
Thank you, Teresa, for sharing your thoughts on all of these changes.