Get a Head Start to Meet Training, Competency Requirements in New Rule
Andy Kramer, MD
2/1/2019
Up to this point, competency assessment and training programs have not been a major focus of regulation. With the daily challenges of resident care, training can be seen as an added burden. Thus, an important place to start is leadership establishing a culture in which increasing competency is rewarded, and transparency is encouraged to identify when staff require additional training.
According to Centers for Medicare & Medicaid Services guidance to surveyors, “Competency is a measurable pattern of knowledge, skills, abilities, behaviors, and other characteristics that an individual needs to perform work roles or occupational functions successfully.” The requirement is: Staff are able to provide care in a manner that reflects standards of practice, and, if called upon, can explain and demonstrate the skills and behaviors required to care for their residents. Competency defined in this way is intrinsically rewarding and can lead to improved staff satisfaction.
The goal in a competency-based training program is to proactively identify the “knowledge, skills, abilities, behaviors, and other characteristics” that a staff member requires based on the needs of the residents for whom she or he is caring. With nursing centers admitting increasingly frail and higher-acuity residents, the underlying intent of the facility profile included in the facility assessment is to identify residents’ care needs.
Also included in the facility assessment is the expectation that competency will be measured in some way that can discern when additional training is required.
Increasing specialization within and across nursing centers requires a much more tailored approach to training. Some nursing centers or units are treating residents with Peripherally Inserted Central Catheter (PICC) lines, others care for residents with severe wounds, while others are managing late-stage dementia and end-of-life care. Ensuring that staff who care for these residents have the competencies that they require involves assessing competency and then tailoring training programs to individual units or staff.
Not surprisingly, adverse events can be the first sign of staff competencies that are lacking. Highlighted throughout the new regulations, Quality Assurance and Performance Improvement programs are expected to address adverse events and prioritize training in these selected areas to prevent reoccurrences. The response to such events, however, requires a full and documented assessment of staff competency that contributed to the adverse event going beyond a single resident or single staff person.
A key staff competency that is often overlooked and now emphasized in the regulations is the ability to identify and address changes in condition before they progress. Subtle changes in cognition, behavior, activity, eating, or sleep may be the early clues of an underlying clinically significant change. If recognized and communicated to those with appropriate training, they can be treated appropriately and in a timely manner.
Once necessary competencies are identified, training can take on whatever form is most applicable to the situation, whether one-on-one mentoring, in-services, online courses, or other training methods. Whatever the training approach, some form of measurement is required to ensure that staff can “perform work roles or occupational functions successfully.”