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Quarterly Risk Managment Tip

State Operations Manual (SOM) Surveyor Guidance Revisions Related to Psychosocial Harm in Nursing Homes

All administrative staff should review the recent changes to the State Operations Manual (SOM) "Surveyor Guidance Related to Psychosocial Harm in Nursing Homes" in order to adequately prepare and comply with state survey expectations. Those changes were announced in a survey and certification memo to state survey agency directors on March 25, 2016.

In the memo, the CMS has revised guidance at F329 in Appendix PP. Revisions include:

  • Removing medication tables to make F329 easier to use;
  • Replacing medication tables with up-to-date medication resources; and
  • Revising Deficiency Categorization examples to show that noncompliance at F329 can cause significant psychosocial harm.

The CMS requested feedback from surveyors about the medication tables. While the tables contain useful information, they have not been routinely updated and CMS determined that providing up-to-date medication resources would be more helpful to surveyors. The new resources provide information on use, side effects, adverse consequences, drug classifications and interactions. Additionally, some of the current deficiency categorization examples show a combination of psychosocial and physical harm. The revised examples show how surveyors may cite F329 when psychosocial harm alone occurs.

The CMS also has added language to 14 other F tags listed below. While surveyors may find negative psychosocial outcomes related to any regulations, these areas may be more susceptible to a negative psychosocial outcome or contain a psychosocial element that may be greater in severity than the physical outcome:

  • F221-F226
  • F241-F242
  • F246
  • F248
  • F250
  • F310
  • F320
  • F353

The new language in each tag emphasizes the risk of psychosocial harm associated with noncompliance at specific regulations and refers surveyors to the Psychosocial Outcome Severity Guide.

Lastly, language has been added to the Psychosocial Outcome Severity Guide in Appendix P to reference F tags where residents may be more at risk for actual or potential psychosocial harm. Visit the Centers for Medicare and Medicaid Services to review these revisions in more detail.

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