​F-tag 656, failure to develop and implement a comprehensive care plan, has been on the top 10 deficiencies list for years. Although this is not a new regulatory requirement, facility staff still struggle to achieve compliance with care planning during annual and complaint surveys.

Negative and siloed views such as, “No one looks at the care plan anyway” or “Only the nurse assessment coordinator is allowed to update the care plan,” serve only to further distance the care plan from its actual intent. While some may mistakenly view it as useless paper compliance, care plans should be viewed as a valuable tool for all staff.

The overall intent of the care plan is to articulate an approach to meet the resident’s goals and preferences and address medical, physical, mental, and psychosocial needs. However, care plans often look instead like lists of general interventions for nonspecific problems, which cannot actually drive resident care.

Refocusing the development and use of the care plan as a valuable tool for the interdisciplinary team (IDT) may help to provide more resident-centered care, improve outcomes, and reduce the risk of receiving an F656 citation during survey.

Redefine the Care Plan as an Invaluable IDT Tool

The guidance provided in the “State Operations Manual (SOM)” for §483.21(b) requires that “facility staff must work with the resident and his/her representative, if applicable, to understand and meet the resident’s preferences, choices, and goals during their stay at the facility.” However, the regulation allows the facility to determine how this process will be completed and to delegate to appropriate staff members.

The guidance continues that, “the facility must establish, document, and implement the care and services to be provided to each resident to assist in attaining or maintaining his or her highest practicable quality of life.”

While this regulation is well-known to most facility staff and is used to develop the comprehensive care plan, the final product often falls short of becoming an ongoing IDT tool to drive the care and services that the resident receives daily. The focus must be on developing the care plan to meet the needs and preferences of the resident, which will meet the regulatory requirements. However, if the focus is on checking a box for regulation, the team will miss critical elements or interventions.

If a physician asks, “What are we doing for Mr. Jones’ chronic obstructive pulmonary disease [COPD]?” The answer, from medication to diet, should be articulated in the care plan, providing the full holistic approach from the IDT. If Mrs. Johnson’s daughter asks what the facility is doing to prevent her mother from falling, all current interventions, from activities to rehabilitation, should be present in the care plan.

Using the care plan as a collaborative tool among all departments helps align the care and services the resident receives to assist them toward their goals. However, to achieve this, facilities must establish clear expectations regarding the level of detail and enforce and monitor timely updating.

If the team shifts its focus from meeting the minimums of regulatory requirements to instead elevate the purpose of the care plan, they can accomplish both by more effectively driving the care and services for the resident.

Self-Identify Problems with Care Planning

Care plans can come in various shapes and sizes; they may be handwritten on paper, completed electronically and printed, or maintained in electronic medical records (EMRs). Although EMRs have many benefits, they can also leave some gaps. Often, EMR users add interventions by simply checking an electronic box, which can lead to generic care plans that are not resident-centered.

Ready-to-go interventions often require individualization once added to the care plan. Failing to individualize results in confusing and incomplete care plans.

While direct care staff should frequently be accessing and updating the care plans, clinical leaders should also monitor for compliance and the quality of these updates. If a resident’s care or interventions have changed, did the team member responsible for the change update the appropriate care plan? Have resolved interventions been appropriately archived? Are the care plans easy to read for non-medical individuals?

Each time clinical leaders identify an incomplete or generalized intervention, or failure to timely update, they also identify a potential survey tag. While the process of monitoring and identifying these problems may be labor-intensive initially, as the facility’s culture adopts the care plan as a tool, the task becomes easier.

Remove the Siloes

Often, staff develop multidisciplinary care plans and believe they are creating interdisciplinary care plans. The key difference is that multidisciplinary care plans focus on the discipline, not the resident. One way to move toward a successful interdisciplinary care plan is to focus on the resident and their actual or potential needs.

For example, often the dietary department is responsible for completing section K of the Minimum Data Set, Swallowing and Nutritional Status. If a resident is coded as having a therapeutic diet, such as a diabetic diet, it will trigger the nutritional status care area assessment (CAA). This may result in the dietary manager or dietitian creating a care plan by focusing on the triggering reason.

The problem statement may read, “Mr. Jones receives a therapeutic diabetic diet due to having a diagnosis of diabetes.” This type of siloed care planning does not allow for an interdisciplinary approach because it does not focus on the resident’s needs. The resident’s need is not for a therapeutic diet, but rather, the management of his diabetes; the therapeutic diet is just one intervention the IDT provides the resident.

When the team shifts the focus to the resident’s needs and the resident’s goal is established with the team, the care plan becomes the IDT’s holistic approach to addressing these needs. As the road map to care, it is used to measure progress toward goals and ensure the resident’s preferences are being met.

The SOM, §483.21(b), states, “Care planning drives the type of care and services that a resident receives. If care planning is not complete, or is inadequate, the consequences may negatively impact the resident’s quality of life, as well as the quality of care and services received.”

Include the Resident

Among the tools available to surveyors are the Long-Term Care (LTC) Critical Element Pathways (CEPs). While there are over 40 tools, there is not one specifically for care planning. However, there are numerous pathways, from activities to behavior, and emotional status to nutrition.

All ask the same question: Did the facility develop and implement a comprehensive person-centered care plan that includes measurable objectives and time frames to meet the resident’s medical, nursing, mental, and psychosocial needs and includes the resident’s goals, desired outcomes, and preferences?
If this was not achieved, the facility will receive a F656 citation.

It is not enough to address what the IDT is doing for the resident’s needs—the resident must play an active part in developing the goals, expressing to staff what his or her desired outcome is, and the staff must understand his or her preferences for care. And just like updating the care plan when changes occur, the resident’s goals and preferences must be frequently reviewed with the resident to ensure it continues to reflect those goals and preferences.

Jessie McGill, RN, RAC-MT, RAC-MTA, is a curriculum development specialist for the American Association of Post-Acute Care Nursing (AAPACN). She can be reached at jmcgill@AAPACN.org.