07/24/2019

ODH: Legionnaires’ Disease in Ohio, Citation Trends and Tips, Complaint Letters

LeadingAge Ohio participated in the Ohio Department of Health’s (ODH) quarterly provider association meeting on July 10. A summary of the updates is as follows:

Survey Updates

The average survey timelines are: 13.5 months for skilled nursing facilities (SNF), 13.7 months for residential care facilities (RCF), and 12.1 months for intermediate care facilities (ICF-IID).

Legionellosis Disease (LD) and Environmental Response for Healthcare Facilities ODH shared that Ohio is the second highest state with reported cases of legionnaires’ disease for 2018, with 930 confirmed cases. This represents approximately a 55% increase from 2017. ODH requests the assistance of healthcare facilities to respond to those cases which are healthcare-associated, which are defined as those cases when the individual resided in the facility the entire 10-14 day incubation period OR where two or more cases are detected. 

The Centers for Disease Control & Prevention (CDC) recommend that public health officials perform a full investigation for the source of Legionella in a facility upon identification of:

• §  ≥1 case of definite healthcare-associated Legionnaires’ disease at any time
• §  ≥2 cases of possible healthcare-associated Legionnaires’ disease within 12 months of each other

 ODH provided immediate response guidance.

 RCF survey clarifications

ODH shared that surveyors will not cite an assisted living provider if a resident refuses to see their primary health care provider for the annual health assessment if the record clearly reflects the refusal. ODH also clarified that their surveyors should review disaster drill compliance by looking at the 12 consecutive rolling months, not calendar year per the Ohio Revised Code. ODH surveyors should not be asking for transfer notices according to the nursing home requirements of participation.

SNF Staffing Scrutiny

The Centers for Medicare & Medicaid Services (CMS) are providing the list of nursing homes with payroll-based journaling (PBJ) staffing concerns to ODH on a monthly basis for them to use during surveys when reviewing staffing.

SNF Health Inspection Citation Trends

Seven of the top ten overall citations in Ohio for 2019 are consistent with the top ten citations in 2018. Of significant importance, F677 ADL decline is the sixth highest cited F-tag (this was not a top ten F-tag in 2018). The 2018 citation trends can be found here.  

SNF Life Safety Code Citation Trends

Nine of the top ten K-tag citations in 2019 are the same as 2018. K-520 is the new K-tag now rising to the top eighth highest cited. Citations for K-521 include smoke/fire dampers not being maintained/installed correctly, corridors used as a plenum, heating, ventilation, and air conditioning not installed or maintained according to code and the manufacturer’s specifications. ODH provides LSC tips which can be found here.

Complaint Letters

As requested by stakeholder associations, ODH provided samples of the complaint letters (Certification Unsubstantiated Disposition Letter, Certification Disposition Letter, Licensure Only Disposition Letter and Licensure Only Unsubstantiated Disposition Letter) that are sent to the person who makes a complaint after the complaint survey is completed. Comments regarding the letters may be shared with Stephaie DeWees at sdewees@leadingageohio.org. 

If you have a question that you would like answered at LeadingAge Ohio’s quarterly meetings with ODH, send it to Stephanie DeWees at sdewees@leadingageohio.org.