Vital Compliance Insights

We shift from facility-level thinking to the corporate level and lay out what a systems-based approach looks like when an organization has multiple facilities. We also argue that a system only protects quality and compliance when corporate leaders verify it is truly being carried out.• corporate mission and vision translated into usable policies and procedures• leveraging corporate resources and talent to support facility teams• a replicable “Guardian Angel” rounding program as a measurement system• using rounding data to drive actionable quality improvements• adding targeted checks when trends emerge such as resident falls• monitoring as the critical step to confirm implementation and effectivenessPlease feel free to reach out to Verity Consulting at VerityTeam.com if you'd like further assistance with your healthcare compliance needs.

We break down what a systems-based approach really means in nursing home quality and compliance and why a solid process beats relying on individual effort. We share a practical meeting and worksheet example, plus how to adapt when real-world disruptions threaten consistency. • shifting focus from individual performance to repeatable systems • using daily interdisciplinary meetings as a dependable communication process • building meaningful tools and worksheets that connect multiple roles • avoiding disengagement when processes are not followed consistently • tweaking workflows when schedules and competing demands interfere • creating a culture where staff feel safe to speak up • balancing flexibility with accountability to protect quality and compliance Please feel free to reach out to Verity Consulting at VerityTeam.com if you'd like further assistance with your healthcare compliance needs. 

We build on fall prevention and root cause analysis by asking compliance committees to take a deeper look at resident falls through targeted audits. We share two practical tools to guide record reviews, surface contributing factors, and strengthen a culture of safety and readiness across the whole facility.• Building on prior fall prevention conversation and resident experience• Using compliance and QAPI as an extra set of eyes• Auditing records for missed root cause signals• Focusing reviews on high fall risk residents• Investigating residents with frequent falls for patterns• Using the AHRQ On-Time Falls Prevention worksheet• Checking whether staff training is enough to mitigate falls• Using the Alliant Health Solutions fall prevention toolkit• Looking beyond the fall to behavioral health and other changes• Treating fall prevention as an interdisciplinary team responsibility• Reinforcing survey readiness through consistent practices and engagementI want you to take a look at those blogs

A troubling statistic sits at the center of today’s conversation: 43% of nursing home falls with major injury and hospitalization went unreported through the MDS. We dig into what that means for resident safety, survey outcomes, quality measures, and reimbursement—and how to fix it fast. Joining me is Janeen Earwood, a physical therapist with four decades of experience in long‑term care, rehab leadership, and analytics. Together, we connect the dots between OIG’s findings, CMS’s plans to validate MDS entries with Medicare and Medicaid claims, and the operational steps facilities can take to prevent harm while protecting data integrity.

Join Allan and Anne as they explore a tough topic that everyone struggles with: grief. Anne shares her personal stories about her journey as a caregiver, and how we can help each other remain strong and feel supported in the midst of sadness.www.verityteam.com 

Welcome to Verity's Caregiving Podcast Series! Join cohosts Anne Blust and Allan Stegemann as they navigate the crucial, compassionate, and complicated world of caregiving. Through sharing personal stories and enlisting guests from different facets of the caregiving world, learn from and relate to other humans experiencing the many ups and downs that come with caring for others.www.verityteam.com

Numbers can light the way or lead us astray. We break down how to build dashboards in long-term care that leaders can actually trust, from defining a “fall with major injury” to validating every step between an incident report and a board-ready chart. As a registered nurse and healthcare analyst, I share a practical blueprint for turning quality data into safer care, faster decisions, and fewer surprises.

We map a systems approach to antipsychotic use in nursing homes, from admission screening to documentation, coding, and survey readiness. Our goal is a practical stewardship model that protects residents, preserves data integrity, and withstands CMS scrutiny.• facility assessment confirming behavioral health capacity• pre-admission screening and verified diagnoses• CMS exclusions and how to document them• pharmacy reconciliation and indication clarity• ordered vs administered tracking with exception flags• alignment of claims, MDS, and ICD coding• nonpharmacologic strategies and target behavior tracking• gradual dose reduction considerations for long-stay residents• hospice-related use and how to explain it• education plans for nurses, providers, and billing• antipsychotic stewardship led by the compliance committee• escalation to psychiatric and neurocognitive specialistsPlease feel free to reach out to Verity Consulting at VerityTeam.com if you'd like further assistance with your healthcare compliance needs

We unpack how CMS will monitor antipsychotic use in nursing homes, why the national average is changing, and what datasets will be cross-checked to produce public quality measures. We set the stage for part two, where we dig into practical steps to strengthen documentation, data integrity, and care processes.• OIG findings and the CMS refocus • reasons for increased oversight and risk signals • how MDS and claims will be cross-referenced • shift in national average to 16.98% • implications for star ratings and care compare • focus on accurate capture, verification, and data integrity • preview of nuts-and-bolts actions in part twoPlease feel free to reach out to Verity Consulting at Verity Team.com if you'd like further assistance with your healthcare compliance needs

We trace how OIG’s guidance elevates patient safety and quality from ideals to daily compliance work, and share lessons from Corporate Integrity Agreements that separate paper programs from living systems. Practical tools, clear dashboards, and a culture of “why” turn metrics into safer resident care.• OIG focus on quality and patient safety as compliance outcomes• Building a facility framework with clear indicators and thresholds• Using dashboards to measure, share, and act on trends• False claims risk tied to substandard care and billing• Lessons from external monitoring and CIAs• Culture of inquiry at board and frontline levels• Resources from CMS, AHRQ, and NIH for frameworks• Root cause analysis for falls and adverse events• Competency alignment with acuity and specialized units• Walking rounds for real-world validation of safe practicePlease feel free to reach out to Verity Consulting at VerityTeam.com if you'd like further assistance with your healthcare compliance needs

We unpack the OIG’s nursing facility guidance on compliance education and show how to move from generic modules to risk‑based, competency‑driven training that protects residents. We connect risk assessments, CMS alignment, and real‑world methods like Gemba rounds to build proof of learning and safer care.• annual, data‑driven risk assessment guiding training focus• tailoring education to resident populations and high‑risk services• aligning CMS requirements of participation with OIG expectations• proving competence with skills checks and just‑in‑time coaching• clear access to compliance officer, committee and safe reporting• onboarding and validating temporary and contracted staff• department‑specific and board‑level training needs• multilingual, culturally aware materials for a diverse workforce• enforcement, remediation and meaningful incentives for completionPlease feel free to reach out to Verity Consulting at VerityTeam.com if you'd like further assistance with your healthcare compliance needs

We examine how the federal shutdown disrupts nursing home oversight, why CMS triaged surveys to emergencies, and the risks created by fewer inspectors and furloughed staff. We share steps facilities can take to protect residents, drawing lessons from the OIG’s pandemic report.• status of the shutdown and date context • CMS priorities for complaint investigations and revisits • suspension of recertification and initial surveys • state surveyor staffing gaps and missed annual surveys • risks from reduced oversight, abuse and neglect concerns • lessons from the June 2024 OIG report • contingency planning for monitoring, QAPI and communication • expectations for future cause-and-effect reportingPlease feel free to reach out to Verity Consulting at VerityTeam.com if you'd like further assistance with your healthcare compliance needs

We examine how CMS F841 and new OIG oversight raise expectations for nursing home medical directors, demanding visible engagement, better policies, and data-informed leadership. We share field lessons on antipsychotics, facility assessment, and building dashboards that support real accountability.• CMS shifts from F501 to F841 and clarifies medical director duties• OIG focus on engagement, visit frequency, and compensation integrity• Risks of absent or passive medical directors in daily care• Antipsychotics oversight, diagnostic accuracy, and documentation alignment• Hands-on leadership beyond QAPI with nursing and administration• Facility assessment that reflects the real resident mix and needs• Data and AI dashboards to drive timely, targeted action• Contracts, coverage, and accountability that sustain engagementPlease feel free to reach out to Verity Consulting at VerityTeam.com if you'd like further assistance with your healthcare compliance needs

Accurate MDS completion has become a regulatory lightning rod as the OIG and CMS intensify their scrutiny of long-term care documentation. This shift isn't merely procedural—it signals a comprehensive effort to identify potential fraud and ensure residents receive appropriate care based on accurate assessments.The recent OIG work plan specifically targets resident falls resulting in major injuries, with investigators cross-referencing hospital claims against facility MDS documentation. When surveyors identify three or more examples of inaccurate MDS completion—now defined as a "pattern"—these findings may trigger referrals to OIG regional offices for fraud investigations. Beyond falls, diagnoses like schizophrenia are receiving particular attention, as inaccurate coding can significantly impact care approaches and medication regimens.For facility leaders, this heightened scrutiny demands a systematic response. Start by ensuring your MDS coordinators have proper certification and education, then verify that all staff contributing documentation understand what they're recording. Implement regular audits to catch discrepancies before they become patterns, and foster interdisciplinary communication so different departments use consistent language and observations. Your compliance committee should conduct risk assessments, particularly for resident populations with high fall risks or complex diagnoses, and report findings transparently during QAPI meetings.The stakes couldn't be higher—inaccurate MDS completion affects not just regulatory compliance but also reimbursement rates, Five-Star ratings, and most importantly, resident care quality. By strengthening your documentation systems now, you'll protect both your residents and your organization from the consequences of this unprecedented regulatory focus. Need guidance navigating these changes? Reach out to Verity Consulting for specialized assistance with your healthcare compliance challenges.

OIG 2023-2024 Compliance Guidance for Long Term Care Facilities is summarized to highlight importance of a compliance committee and the responsibility to assist the chief compliance officer to develop a robust facility risk assessment. From that assessment the committee would need to develop meaningful and accessible policies and procedures to guide all levels of the facility staff and consultants of their roles and responsibilities in maintaining healthcare compliance. 

In this episode, I will discuss the OIG November 2023 Compliance Officer Roles and Responsibilities guidance. The compliance officer has a responsibility to develop policies and procedures, conduct risk assessments, provide education and training, and promptly investigate any reports of abuse or fraud. They must also foster a culture of open communication and transparency within the organization and have open access to the board to report concerns and updates on the compliance program. 

In this podcast episode, the host discusses the 2023 and 2024 updates to OIG's compliance program guidance (CPGs). These updates include a move to publishing the CPGs on the OIG website and the addition of a section on quality and patient safety. The host emphasizes the importance of incorporating quality and patient safety into compliance programs and discusses their personal experiences as a health care analyst working with corporate integrity agreements. The episode concludes with a quote from the OIG summary,

 Skilled nursing facilities are facing changes in CMS survey guidance regarding unnecessary use of psychotropic medications. CMS is closely monitoring the use of these medications, which can be considered chemical restraints, and is asking facilities to focus on behavior interventions to minimize use. CMS is emphasizing the importance of professional standards of practice and the role of the medical director in monitoring the use of these medications. The use of psychotropic medications, including antipsychotics, antidepressants, anti-anxiety drugs, and hypnotics, in elderly residents in nursing homes should be carefully monitored and documented by prescribing practitioners. These medications can have serious side-effects and should only be used for residents with a clear diagnosis of a mental health condition or medical condition. The use of non-pharmacological interventions should be attempted before resorting to psychotropic medications. CMS has requested that skilled nursing facilities develop multidisciplinary teams to monitor psychotropic medication use in their residents, due to concerns about unnecessary use, adverse effects, and lack of comprehensive assessments. CMS is also moving psychotropic medications to F605 in an attempt to highlight the importance of proper medication management that has the potential for chemical restraint effects. This episode focuses on why CMS is making this request and the risks associated with psychotropic medication use in the elderly. A follow-up episode will discuss the need for comprehensive assessments, behavior interventions, and chemical restraints as a result of inappropriate use of psychotropic medications. 

SummaryThe CMS has released updated guidance on the long-term care survey process, focusing on accuracy of the MDS, medical director responsibilities, psychotropic medications and chemical restraints. In addition, the CMS issued clarifications for enhanced barrier precautions, pain management, quality assurance and performance improvement, health care equity, and prohibits certain language in admission agreements.  It is important to recognize that healthcare surveyors will be looking for supporting documentation for the use of psychotropic medications.  This episode discusses the updated Appendix PP which contains critical element pathways which  surveyors will use during the nursing home survey process. These critical element pathways include the unnecessary medications pathway and the discharge pathway. The unnecessary medications is an important resources tool all facilities should carfully review especially for residents with dementia and schizophrenia diagnoses and receiving psychotropic medications.