[RM23]

hh

Are you all aware that the 'new' proposed language for ESRD regulations has been published to the Federal Register (2/4/05)).. This means that these proposed regs are open for public comment for ninety days, at which time, public comments are reviewed by those developing new regulations. I would suggest that anyone who is involved with dialysis/ESRD takes time to read these as they will affect staff and patients. The new regulations are not prescriptive as the existing ones are and are more outcome oriented. Additionally, many existing regs are being deleted. Now is the time to be heard if you have concerns about delivery of care. Please take time to read.
put in your search engine 'federal register february 4, 2005',, (without quotes) then click onto CMS - ESRD and you can pull up.. 50 pages of good worthwhile reading..........

[imperial]

Yes, I agree. Everyone involved should read and make public comment. These regulations have not been revised in over 30 years, now what does that tell you?

[jnette]

To effictively implement these new (as well as all current standing regulations) the need for adequate staffing ratios MUST be addressed.

It seems like there is always more and more piled on us (and often the new changes ARE justified, I'm not denying that improvements are timely or necessary!) but the staffing ratios remain the same.

It is becoming next to impossible to continue to provide the detailed attention and care our patients deserve without the proper and necessary amount of staff.

I do wish the Federal Guidelines would addresse THIS as well.. so these for profit corporations would be forced to comply.


grrrrrrrrrrrrrr...rrr !!!

[jnette]

hmmmmmmm... just glanced over the headlines of the changes and found that we have already incorporated most of these, with VERY few exceptions...

will be reading more in teh days ahead.. thank you for the link info !

[imperial]

The proposed language states that states, some, not all, already have staffing ratios in place which are to be followed. However, if there is negative outcome the units can be cited for insufficient staffing if it relates to same.

Again, many states have this in place already. Corporations are going to do what is cheapest, as we well know. Also, it is the dialysis techs that do most of the care.

I was glad to see that the CDC recommendations are now mandated as this is a great problem in units.

[jnette]

Originally Posted by imperial

The proposed language states that states, some, not all, already have staffing ratios in place which are to be followed. However, if there is negative outcome the units can be cited for insufficient staffing if it relates to same.

Again, many states have this in place already. Corporations are going to do what is cheapest, as we well know. Also, it is the dialysis techs that do most of the care.

I was glad to see that the CDC recommendations are now mandated as this is a great problem in units.

imperial..

the staffing ratio is lip service only.

Yes, we have now been certified to do "Ultra Care".. a big deal for FMC. While there are some great aspects to the "upgrade", and we have incorporated all of them, the one component NOT being addressed (yet greatly touted in Ultra Care) is the staffing. It remains on paper only. IF this were to be enacted, it would be the best thing that ever happened to dilaysis. But as you say, this would certainly cost $$ and I don't look forward to the company implementing this aspect of it anytime soon.. if ever.

Again, it is a wonderful marketing tool.

As it is, our NM is being pressed to make sure the staff has NO overtime.

Which is next to impossible, as they continually increase our census and the patients we are now accepting are more and more "disabled"... having to employ the use of the hoyer lift, etc. is all very timeconsuming. Add to that all the truly TECHNICAL tasks we end up doing so they won't have to send out the technical crew.

These companies speak with forked tongue.

P.S.

Can you provide a link to the staffing ratios you mentioned above ?

[jnette]

imperial..

I was able to find this, but my gosh, this is SO vague it can be interpreted any way at all ! And we all know how the corporations will choose to interpret !

I mean just what is the definition of "adequate staff in /adequate numbers"??? Could they not have been more SPECIFIC?


Sec. 405.2162 Condition: Staff of a renal dialysis facility or renal
dialysis center.

Properly trained personnel are present in adequate numbers to meet
the needs of the patients, including those arising from medical and
nonmedical emergencies.
(a) Standard: Registered nurse. The dialysis facility employs at
least one full time qualified nurse responsible for nursing service.
(See Sec. 405.2102.)
(b) Standard: On-duty personnel. Whenever patients are undergoing
dialysis:
(1) One currently licensed health professional (e.g., physician,
registered nurse, or licensed practical nurse) experienced in rendering
ESRD care is on duty to oversee ESRD patient care;
(2) An adequate number of personnel are present so that the patient/
staff ratio is appropriate to the level of dialysis care being given and
meets the needs of patients; and
(3) An adequate number of personnel are readily available to meet
medical and nonmedical needs.
(c) Standard: Self-care dialysis training personnel. If the facility
offers self-care dialysis training, a qualified nurse is in charge of
such training (see Sec. 405.2102.)

[41 FR 22511, June 3, 1976. Redesignated at 42 FR 52826, Sept. 30, 1977,
as amended at 43 FR 48953, Oct. 19, 1978; 51 FR 30362, Aug. 26, 1986]

[jnette]

Actually, I'm having trouble finding the new proposed language.. any direct links? Thanx !

[imperial]

J'nette: What is ultra care? What does it encompass in training? What is the goal? In other words, what IS ultracare? Can you give a few examples of ultracare?

Each state has their own staffing ratios. To be honest, these are in hospitals and nursing homes and I really don't know how they apply to renal outpt units. I do know, according to the regulations, that some states do have ratios for renal units. The states are specifically mentioned in the proposed language, although I do not remember. I do know, from my reading, that in California recently, the Governor vetoed the bill that would have mandated staffing ratios in hospitals.

Do other companies have the same as FMC i.e. ultracare?

[jnette]

Originally Posted by imperial

J'nette: What is ultra care? What does it encompass in training? What is the goal? In other words, what IS ultracare? Can you give a few examples of ultracare?

Each state has their own staffing ratios. To be honest, these are in hospitals and nursing homes and I really don't know how they apply to renal outpt units. I do know, according to the regulations, that some states do have ratios for renal units. The states are specifically mentioned in the proposed language, although I do not remember. I do know, from my reading, that in California recently, the Governor vetoed the bill that would have mandated staffing ratios in hospitals.

Do other companies have the same as FMC i.e. ultracare?

Cna you lead me to a link which provides the listing of the states that DO have ESRD outpatient renal clinic staffing ratios?

re Ultra care:

it is the new FMC deal, and they make a really BIG deal of it.

It would take me forever to list all the benefits/advantages, but I'll see if I can find you a link, ok?