CMS Critical Element Pathways

Lisa Volk in Clinical & Quality

How do I begin to prepare for the new survey process? The newly released CMS Critical Element Pathways are a perfect place to start. These tools can help manage quality in healthcare settings and standardize care processes. The new survey method is a blend of traditional and QIS survey. The critical pathways are included in this new process. Each pathway provides detailed information for the surveyor to follow during survey. Some of the areas for review are: resident records, staff and family interviews, as well as observations. Use these critical pathways as a helpful resource, review the sections below and educate the staff to ensure compliance in each of these areas. Additionally, the last section of the pathway includes the critical element decision making related to citing of deficiencies. All the critical pathways can be found at: 

https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/GuidanceforLawsAndRegulations/Downloads/LTC-Survey-Pathways.zip 

Here are some examples of what to look for under the environment critical element…. See full critical element pathway in the above link.

Accommodation of Needs:  Review this CE if there are concerns regarding the resident’s accommodation of needs by the resident, representative, or through observations.  Interview staff regarding the identified concern to determine how the facility has addressed the concern:  • Room set up so the resident can get around easily, get to and from the bathroom, use of the sink, or accessing drawers and closets. • Roommate’s personal items taking over the resident’s space.  • Call light in reach in the resident’s room, toilet, and bathing facilities, and the appropriate type used.  • Enough light in the resident’s room to do what the resident wants.  • Adaptive equipment available and used. 

1. Do residents receive services with reasonable accommodation of resident needs and preferences except when to do so would endanger the health or safety of the resident or other residents?         Yes     No F558       NA

Call Light Functioning: Review this CE if there are concerns with the call lights not functioning by the resident, representative, or through observations.  Interview staff if the resident or representative complained about the call lights not functioning or observations that the call system is not functioning to determine how the facility has addressed the concern.

2. Are call systems in all areas functioning properly?      Yes    No F919       NA

Sound Levels:  Review this CE if there are concerns by the resident, representative, or through observation of uncomfortable sound levels.  Interview staff if the resident or representative complained about comfortable noise levels or observations revealed uncomfortable sound levels to determine how the facility has addressed the concern.

3. Are comfortable sound levels maintained in all areas?       Yes    No F584       NA

Temperature Levels: Review this CE if there are concerns by the resident, representative, or through observations with comfortable temperature levels maintained  Interview staff if the resident or representative complained about comfortable temperatures or observations revealed uncomfortable room temperatures (too cool or too warm) to determine how the facility has addressed the concern. 

4. Are comfortable and safe temperatures maintained in all areas?       Yes    No F584   NA 

Lighting Levels: Review this CE if there are concerns by the resident, representative, or through observations with adequate lighting levels.   Interview staff if the resident or representative complained about proper lighting or observations revealed inadequate lighting to determine how the facility has addressed the concern.

5. Are proper lighting levels maintained in all areas?       Yes    No F584       NA

Clean Building: Review this CE if there are concerns with the cleanliness of the building by the resident, representative, or through observations.  Interview staff if the resident or representative complained about the cleanliness of their room or building (e.g., walls, floors, ceilings, drapes, resident care equipment, or furniture), or observations revealed an unclean room or building to determine how the facility has addressed the concern. 

6. Are all areas clean?         Yes    No F584       NA 

Building and Equipment Good Condition: Review this CE if there are concerns with the building being in disrepair through observations.  Interview staff if observations revealed the resident’s room, equipment, or building (e.g., transfer equipment, IV pumps, glucometers, thermometers, ventilators, suctioning devices, oxygen equipment, nebulizers, furniture) being in disrepair to determine how the facility has addressed the concern. 

7. Are all areas or equipment in good repair?       Yes    No F584       NA 

8. Is resident care equipment in safe operating condition?         Yes    No F908          NA 

Homelike: Review this CE if there are concerns with the resident’s room being homelike through observations.   Interview staff if observations revealed the resident’s room is not homelike to determine how the facility has addressed the concern. 

9. Are the residents allowed to have personal belongings, to the extent possible, creating a homelike environment?      Yes    No F584       NA 

Lack of Hot Water: Review this CE if there are concerns by the resident, representative, or through observations with the hot water being too cool.  Interview staff if the resident or representative complained about the hot water being too cool or observations revealed the hot water in the resident’s room, bathroom, or bathing facilities is too cool to determine how the facility has addressed the concern.

10. Are water temperatures comfortable?  Yes    No F584       NA

Linens: Review this CE if there are concerns by the resident, representative, or through observations with the linens being soiled.   Interview staff if the resident or representative complained about the linens being soiled or observations revealed soiled linens to determine how the facility has addressed the concern.  Refer to the Incontinence or Infection Control pathways, as needed, for additional investigative guidance.  

11. Are there clean bed and bath linens in good condition available for the resident?          Yes     No F584       NA

Pest Control: Review this CE if concerns are identified onsite.  Interview staff if there are signs of pests or rodents throughout the facility to determine how the facility has addressed the concern.  Review the facility’s pest control program.  Review documentation of pest control intervention (e.g., commercial contractor). 

12. Does the facility maintain an effective pest control program so that the facility is free of pests and rodents?       Yes    No F925       NA 

Ventilation: Review this CE if concerns are identified onsite.  Interview staff if there are odors throughout the facility to determine how the facility has addressed the concern.

13. Is there adequate ventilation in all areas?      Yes    No F923       NA

Handrails: Review this CE if concerns are identified onsite.   Interview staff if there are concerns with handrails being accessible and securely affixed to the walls throughout the facility to determine how the facility has addressed the concern.

14. Are handrails accessible and securely affixed to the walls?       Yes    No F924          NA

Other Environmental Conditions: Review this CE if concerns are identified onsite.  Interview staff if there are concerns with the environment being safe, functional, sanitary, and comfortable for residents, staff, and the public to determine how the facility has addressed the concern.

15. Does the facility provide a safe, functional, sanitary, and comfortable environment for residents, staff, and the public?  Yes    No F921       NA

NYSHFA CONTACT:

Lisa Volk, RN, B.P.S., LNHA
Director, Clinical & Quality Services
518-462-4800