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August 2005

CMS combines F-tags 315 and 316 into one new F315 tag

On June 28, 2005, The Centers for Medicare and Medicaid Services (CMS) issued new surveyor guidance in Appendix PP for incontinence and catheters which combine F315 and F316 into one tag: F315.

The new guidance contains:

Interpretive Guidelines which provide specific definitions clarifying clinical terms related to evaluation and treatment of urinary incontinence and catheter care as well as definitions of the six types of urinary incontinence. The guidelines go on to explain why urinary incontinence is not a normal part of aging. A list of recognized clinical resources on the prevention and management of urinary incontinence, infection, and urinary catheterization is provided to assist the facility in broadening its knowledge base on incontinence care.

Other valuable additions to these interpretive guidelines include:

  • How to involve the resident and his/her surrogate in care decisions relating to incontinence and how the advance directive interplays
  • First steps toward assuring a resident receives appropriate treatment and services to restore as much bladder function as possible or to treat and manage the incontinence
  • What should be considered when completing the comprehensive assessment
  • Types of interventions, including behavior programs, intermittent catheterization, medication therapy, use of a pessary, use of absorbent products, toileting devices and external collection devices
  • Dealing with skin-related and catheter-related complications
  • Assessment of the resident with an indwelling catheter
  • Identification and treatment of urinary tract infections

New Investigative Protocols assist the facility in determining:

  1. the indications for catheter use;
  2. the adequacy of interventions to prevent, improve and/or manage urinary incontinence;
  3. whether appropriate treatment and services have been provided to prevent and/or treat urinary tract infections.

These protocols include detailed assessment and care plan guidelines for incontinence and catheter care making it easier for facilities to maintain compliance with F315. The care plan guidance includes not only what should be written in the care plan, but also the criteria for care plan revision, such as the outcome and/or effects of goals and interventions, a decline or lack of improvement in continence status, complications associated with catheter
usage, etc.

The investigative protocol for F315 includes a lengthy section on determination of compliance detailing a synopsis of the F315 regulation, criteria for compliance, the basis for noncompliance of F315 and a list, with explanations, of potential tags for additional investigation.

Deficiency Categorization - Compliance and severity guidance consists of specific criteria for determining facility compliance when caring for incontinent residents and residents with catheters. Scope and severity guidelines provide examples of possible negative outcomes that may result when the facility has deficient practices; the degree of harm related to the noncompliance; determination of whether the noncompliance requires immediate correction in order to prevent serious injury, harm, impairment, or death to one or more residents. Severity levels from No Actual Harm to Immediate Jeopardy to Resident Health or Safety are defined as they relate to F315.

Sandra Kay Scott, RN, BS
President, Webb Enterprises

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