6Beds met with CCL in Sacramento on March 2, 2016 to review and discuss a draft copy of its upcoming RCFE medication management best practices guide for RCFEs. I attended the meeting in person on behalf of 6Beds and was accompanied via teleconference by fellow 6Beds leader, Cyndy Minnery, R.N.
Here’s a sneak peek at what topics you can expect CCL’s upcoming RCFE medication management guide will cover:
- Designation of Staff to Handle and Store Medication
- New Arrivals with Medication and Refills
- Medication Placed on Hold, Expired or Resident Dies
- Medication is Refused, Missed, or Needs to Be Crushed or Altered
- Medication Set Up, Home Visits, and Medication from Other Countries
- Medication Destruction
Guidance for Specific Medications
- PRN Medication
- Injectable Medications
- Ear and Eye Drops or Nasal Sprays and Over-the-Counter Medications
- Emergency Medication
- Pre-Packaged Medications, Sample Medications, PRN Medication, and Psychotropic Medications
- Medication Training
6Beds provided significant feedback regarding a number of areas addressed in the draft copy of the guide that we feel will result in positive developments for RCFE licensees that will be reflected in the final version of the guide.
Stay tuned for updates regarding these developments and information regarding the release of the guide.
Community Care Licensing (CCL) announced on February 26, 2016 that on Tuesday, March 1, 2016 it would begin online posting of Complaint Investigation Reports (LIC 9099s), making them available for public online consumption for the first time via its Transparency Website.
Given that 6Beds has become aware of a number of inconsistencies in practice, it has not been entirely clear as to what CCL’s policies are regarding whether a Complaint Investigation Report is classified as either “Public” or “Confidential” based on either the completion status of the investigation or the actual investigation findings. For example, for Complaint Investigation Reports that are not yet completed and where the reports identify that further investigation is required, 6Beds is aware of some of these reports being labeled as “Confidential”, some of them being labeled as “Public”, and some of them not being labeled at all. However, all complaint investigations that are not yet completed should be marked “Confidential” until a resolution is reached.
In general, 6Beds is not opposed to the idea of information being available for public consumption. However, the public should be entitled only to information that is legitimately and legally “Public” and the availability of information should not come at the expense of accuracy, consistency, and fairness. Earlier this week, 6Beds formally registered its concerns regarding this issue with CCL and has sought clarification regarding its policies.
On Wednesday, March 2, 2016, CCL Deputy Director Pam Dickfoss and Statewide Adult and Senior Care Program Administrator Ley Arquisola were kind enough to meet with me to discuss 6Beds’ concerns and to provide clarification. In this meeting, CCL was able to confirm the following:
- Complaint Investigation Reports that indicate that further investigation is required should be marked “Confidential” and not posted to the Transparency Website until a resolution is reached.
- For RCFEs, all Complaint Investigation Reports with approved complaint findings, even if the findings are “Inconclusive” or “Unfounded”, are to be marked “Public”. This is an area that has been a source of confusion for RCFE licensees as many RCFE licensees have been under the impression that “Unfounded” complaint findings are to be labeled “Confidential,” which would make sense. However, CCL has clarified that based on statute all approved complaint findings for RCFEs are “Public”.
- For ARF licensees, however, “Unfounded” complaint findings are “Confidential”. “Inconclusive” and “Substantiated” complaint findings are “Public”.
- Only Complaint Investigation Reports with complaint findings approved after January 1, 2016 will be posted to the Transparency Website. This is positive news because the inconsistencies that 6Beds is aware of are from before January 1, 2016 and 6Beds, therefore, was concerned that Complaint Investigation Reports with complaint findings issued prior to January 1, 2016 would be posted to the Transparency Website.
CCL has also committed to producing a document explaining these policies, which I will distribute once it’s made available. 6Beds is also working internally and with CCL on a process whereby licensees can report to 6Beds any inconsistencies or inaccuracies related to confidential Complaint Investigation Reports inappropriately being labeled “Public” and posted to the Transparency Website. The inquiries from licensees would then be vetted by 6Beds and forwarded directly to CCL headquarters for review and follow-up.
Stay tuned for updates on this issue as they become available.
DSS’ Community Care Licensing (CCL) recently provided 6Beds with a confidential advance draft copy of its upcoming RCFE medication management best practices guide for RCFEs. CCL has asked 6Beds to review the draft copy of the guide and to attend a stakeholder meeting it’s hosting in Sacramento on Wednesday March 2, 2016 for the purpose of providing input and improving upon the medication management guide’s contents.
Stay tuned for another update after the Wednesday March 2, 2016 meeting.