Ombudsman and QIO Roles

Sent: Wednesday, August 07, 2002 12:29 PM
To: All state directors on aging
Cc: AoA Regional Administrators
Subject: MESSAGE FROM THE ASSISTANT SECRETARY FOR AGING

Dear Colleague:

Earlier this year the U.S. Department of Health and Human Services launched a six-state pilot program (in CO, FL, MD, OH, RI and WA) to test the process of publicly disclosing quality measures for individual nursing homes via the "nursing home compare" feature on the Centers for Medicare and Medicaid Services (CMS) website at: http://www.medicare.gov. In addition to providing the measures to the public, the CMS initiative also includes providing new community-based quality improvement programs to nursing homes by Medicare's Quality Improvement Organizations (QIOs), formerly Peer Review Organizations (PROs). CMS plans to implement the initiative in all states this October.

The Administration on Aging's (AoA) National Long-Term Care Ombudsman Resource Center has been providing information and resources about the initiative to the ombudsman network and will continue to ensure that ombudsmen have the most up-to-date information on this important undertaking.

As part of the initiative, CMS and AoA have established a project in the six pilot states to demonstrate the effectiveness of partnerships between the state Long-Term Care Ombudsman Programs (LTCOPs) and the QIOs. A fundamental role of the LTCOP in the partnerships is to educate and advise consumers on how to use the quality measures as one tool in making decisions about nursing home placement and quality of care issues.

Below is a definition of roles and activities of the LTCOPs and QIOs which CMS and AoA developed, based on a similar roles statement developed by the Ohio QIO and LTCOP. Last week CMS provided the document to all the state QIO's. For states that wish to develop QIO/LTCOP partnerships, the paper can be used as guidance in developing state-specific memoranda of understanding on these quality improvement initiatives.

If you have any questions about the paper or the initiative, please contact Sue Wheaton on my staff at 202-619-7585, or by e-mail at: sue.wheaton@aoa.gov.

Sincerely,

Josefina G. Carbonell
Assistant Secretary for Aging

NURSING HOME QUALITY INITIATIVE

Relationship of Quality Improvement Organizations (QIOs) andState Offices of the Long-Term Care Ombudsman (LTCOPs)

This document has been developed by the Centers for Medicare & Medicaid Services and the Administration on Aging for use by Quality Improvement Organizations and State Offices of the Long-Term Care Ombudsman in developing partnerships for the Nursing Home Quality Initiative.

FUNDAMENTAL ROLES

* For purposes of this initiative, QIOs have been given the responsibility to promote awareness and use of publicly reported nursing home quality measures, and to provide assistance to nursing homes in their State which seek to improve performance.

* QIOs will seek to accomplish this by conveying the message that some nursing homes do better than others in regards to quality measures that are important to beneficiaries and their caregivers, and by making available information and assistance to facilities about how they can achieve better performance.

* For the purpose of this initiative, LTCOPs will assist residents, family members, concerned citizens and others with the use of quality measures in nursing home selection and in assessing nursing home care and will assist, as feasible and appropriate, QIOs with other aspects of the initiative.

* CMS and AOA view the roles of the QIOs and the LTCOPs as complementary in this initiative, and encourage QIOs and LTCOPs to develop relationships which support the fundamental roles of each.

QUALITY IMPROVEMENT ROLES AND ACTIVITIES

* QIOs will only work on clinical topics directly related to publicly reported measures.

* QIOs will serve as non-regulatory partners with nursing homes to facilitate quality improvement. Nursing homes work with QIOs on a voluntary basis, and are of course free to use other agents (private consultants, etc) in their improvement efforts.

* LTCOPs investigate/resolve complaints submitted by consumers. LTCOPs, as feasible and appropriate, will draw on this experience to assist QIOs in identifying and working with specific facilities on quality improvement initiatives, consistent with statutory confidentiality requirements.

* QIOs also respond to complaints submitted by or on behalf of beneficiaries. QIOs will inform complainants of the availability of LTCOPs to investigate their complaints, but are expected to respond themselves to any written complaints which they receive.

* LTCOPs publicly advocate for residents of nursing homes, board and care homes, assisted living facilities and similar adult care facilities.

* LTCOPs provide onsite consultation and training to nursing homes regarding issues addressing quality of residents' care and life. Examples may include resident rights, elder abuse, communications with the cognitively impaired, restraint reduction, etc.

* LTCOPs provide an on-going presence in long-term care facilities by monitoring care and conditions and providing a voice for those who are unable to speak for themselves.

* QIOs and LTCOPs are encouraged to collaborate for the purpose of improving quality of life and care for residents of nursing homes.

* LTCOPs are encouraged to share information with QIOs about current quality improvement activities related to these measures that are being conducted in the State. LTCOPs and QIOs are encouraged to explore the potential for working together on such activities. In such collaborations, practitioner-, facility-, or resident- identifiable information which is reported by nursing homes to the QIO is confidential. It cannot be released through the Freedom of Information Act and is protected from disclosure as provided in federal statute and regulations.

* LTCOPs are encouraged to provide information to QIOs that may help them in identifying and providing assistance to facilities, except that the identity of a resident or complainant may not be disclosed without consent of the resident or complainant, as required in Section 712(d)(2) of the Older Americans Act.

* LTCOPs are encouraged to provide information to nursing homes regarding assistance which the QIOs may offer.

COMMUNICATION AND SUPPORT

* QIOs and LTCOPs are encouraged to communicate regularly on all initiative-related activities. QIOs and LTCOPs should provide overviews to each other about their organizations and responsibilities.

* QIOs are encouraged to share information with the State Ombudsman on the publicly reported Quality measures and how they differ from the QIs used by the survey agency.

* QIOs and LTCOPs are encouraged to work collaboratively to ensureconsistency of message and to educate, consumers, providers, media and policy makers regarding quality care in long term care facilities.

* QIOs and LTCOPs are encouraged to work collaboratively on the provision of assistance to consumers regarding selection of longterm care facilities.

EVALUATION

* Both QIOs and LTCOPs will provide input to assist in evaluation of the effectiveness of various processes and policies.