F-tag 689 (Free of Accident Hazards/Supervision/Devices) was the second most frequently cited at the immediate jeopardy (IJ) level during fiscal year (FY) 2021, according to the Citation and Frequency Report from QCOR (Quality, Certification, and Oversight Reports) at the Centers for Medicare & Medicaid Services (CMS). Providers received significantly more IJ-level citations under F689 than any other F-tag except for F880 (Infection Prevention and Control) for the past two fiscal years, and in pre-pandemic FY 2019, F689 was the leader in IJ-level citations.
Typically, providers don’t have the same orientation process for agency staff that they have for new permanent staff, and this can be a problem from an emergency preparedness and safety perspective, especially now that agency staffing has become far more common in nursing homes, says Liz Wheeler, BSN, RN, CHPN, CDP, IPCO, a nurse consultant with LeaderStat in Powell, OH.
“Every nursing home is different—both in terms of physical layout and policies and procedures,” she points out. “If you assume that agency staff can just plug into your system, they could have some significant emergency preparedness and safety training gaps. For example, they may not know where to find your fire extinguishers or what your facility-specific abuse and neglect procedures are.”
The dramatically expanded use of agency staff requires that directors of nursing services (DNSs) and administrators change their mindset around who is staff and who is not, suggests Wheeler. “Everyone on the management team needs to understand that agency staff must be deemed competent in the same ways that actual employees are. They really have to be thought of as full members of the team because an emergency preparedness or safety situation that could lead to an immediate jeopardy is not going to wait for permanent staff members to be at work.”
Providers should make sure that agency staff have some type of onboarding procedure related to emergency preparedness and safety, says Wheeler. “This should focus on anything related to safety, such as your emergency management plans for elopements, fires, and any natural disasters that you plan for, including tornadoes and other severe weather (e.g., extreme heat or cold); your facility’s process for reporting alleged violations of abuse, neglect, exploitation, or mistreatment; how to identify and report suspicion of a crime if that isn’t included in the staffing agency’s training; and your elopement policies and procedures.”
This training of agency staff could take the form of electronic education, a packet of information, or a short meeting prior to or at the beginning of the agency staff member’s first shift, says Wheeler. “However you handle it, you want to do some type of initial education so that agency staff can be deemed competent in your emergency preparedness and safety procedures.”
Follow up with competency measurement, safety rounds
No matter what type of emergency preparedness and safety training providers give agency staff prior to starting work, it’s only the first step, says Wheeler. “Training doesn’t necessarily mean that agency staff really understand your procedures, so follow-up is key.”
That should start with competency measurement, says Wheeler. “You don’t want to, for example, hand an agency staff member a packet of information and say, ‘Sign here to show that you received it,’ without any additional follow-up. You must measure agency staff’s knowledge. That could include a written test or skills observation, depending on the competency being measured.”
Another good way to follow up is for the DNS and other members of the management team to do safety rounds, suggests Wheeler. “You can round while some of your agency staff are working, find out how they are doing in general, and ask safety-focused questions.”
Wheeler offers the following examples of the types of questions that could be asked during rounds:
- Did someone walk you around to check where the fire panels are?
- Do you know what to do if a resident is missing?’
- Do you know where the crash cart or suction machine is?
“By taking a few minutes to have that one-on-one communication, you can re-enforce that initial training on your facility’s policies and procedures and identify gaps that may require retraining,” she points out.
Include agency when conducting additional staff safety trainings
Providers don’t always incorporate agency staff into ongoing safety training and education, but they need to be included, says Wheeler. “For example, in a situation where a facility has an elopement, agency staff should participate in any education that is a component of the abatement plan. Similarly, agency staff should be included if you are doing additional education for a feared situation, such as an upcoming hurricane or wildfire season or elopement procedures for below-freezing conditions.”
In addition, agency staff will need to be provided additional education if a fire drill or other emergency exercise doesn’t go well, says Wheeler. “They should be re-educated, and then you should again circle back to make sure they feel comfortable. For example, you may want to do additional safety rounds.”
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