Pillars of Care

by | Nov 4, 2022 | CMS & OIG, Survey

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Reviewing the Behavioral Health Pillars

The US Department of Health and Human Services (HHS) developed a roadmap for behavioral health integration to address a national mental health crisis.  The current Administration’s strategy is based on three core pillars:

1. Strengthen System Capacity 
2. Connect Americans to Care
3. Support Americans by Creating Healthy Environments

While the HHS Roadmap does not specifically address Skilled Nursing Facilities, it requires efforts throughout the healthcare system in all settings. Facilities should look to establish techniques early to avoid scrambling later on to keep up.

Long-term care facilities were mentioned specifically in the fact sheet from May 31, 2022. Specifically, the fact sheet states:

HHS is launching a new, $15 million funding opportunity to establish a Center of Excellence for Building Capacity in Nursing Facilities to Care for Residents with Behavioral Health Conditions, which will work to strengthen behavioral health care in long-term care facilities by improving mental health literacy and combating stigmatization among staff.

How should nursing homes respond to these initiatives?

When it comes to the Requirements of Participation, the recent QSO (Quality, Safety and Oversight) memorandum #22-19-NH indicates that:

CMS has identified a need to improve guidance related to meeting the unique health needs of residents with mental health needs and SUD (substance use disorder). We clarified that when facilities care for residents with these conditions, policies and practices must not conflict with resident rights or other requirements of participation. 
We further clarified that facility staff should have knowledge of signs and symptoms of possible substance use, and be prepared to address emergencies (e.g., an overdose) by increasing monitoring, administering naloxone, initiating cardiopulmonary resuscitation (CPR) as appropriate, and contacting emergency medical services. We also provided resources and non-pharmacological interventions, specific to residents living with mental disorders or substance use disorders, to assist providers in identifying alternative approaches to care to support this population.”

This indicates an expectation for each facility to develop treatment plans to properly care for residents with mental illness or substance use disorders. Staff should be well educated on treatment options and diagnoses to improve mental health literacy and reduce stigmatism.   Understanding nonpharmacological interventions may also decrease polypharmacy.  Future releases will surely provide more guidance as HHS seeks to achieve their goal.
The MDS assessment remains a central tool in identifying both medical and psychiatric symptoms in nursing home residents.

For those nursing facilities pursuing this new direction, we recommend three pillars specific to mental health and substance use disorder care within SNF’s to get us started:
1. Strengthen ability to care for psychiatric and substance use disorder residents
2. Connect residents to appropriate psychiatric providers and therapy
3. Maintain a supportive and non-stigmatizing environment of care

Our customers continue to age with conditions such as trauma, anxiety, and other psychiatric issues. We expect providing mental health care in SNF’s will continue to be required by both HHS and CMS. Ensuring that you and your staff are ready can help keep you balanced on these three pillars.


QSO-22-19-NH (cms.gov)

HHS Roadmap for Behavioral Health Integration Issue Brief

FACT SHEET: Biden-Harris Administration Highlights Strategy to Address the National Mental Health Crisis – The White House

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