I am writing based on my experiences as a Health Facilities Evaluator Nurse. HFENs for CDPH’s Licensing and Certification section are tasked with visiting Skilled Nursing Facilities to review facility practice to ensure compliance with state and federal regulations and laws. Inherently, our work processes are confrontational. HFENs have realized increased confrontation during COVID-19. Whether it is because emotion and burnout are high, or because facilities find CDC and CDPH guidance too costly, challenging, or difficult, or some other reason, HFENs are experiencing confrontation more than before.
This past weekend, I experienced a facility administrator terminate a CDPH state monitoring visit for COVID-19, after being asked about the role the administrator and/or infection Preventionist played in the facility’s decision about a PUI’s (e.g., a person under investigation for COVID-19, for exhibiting signs and symptoms of the virus) bed location. The facility did not comply with CDC recommendations. SNFs operate in an industry regulated 24 hours a day, seven day a week, 365 days a year. To demonstrate compliance, SNFs should not be allowed to demonstrate lesser importance toward infection prevention and control compliance than their GACH (e.g., acute care hospitals) counterparts. Administrators of SNFs perform licensed work, for their licensed facility and pursuant to an administrator license. Honest, candid discussion with state regulators should be a requirement for each license. That an administrator can terminate a visit by asserting the subjective feeling of being “bull[ied]” by a surveyor seeking information appropriately and germane to the quality of care is disingenuous.
Our state’s licensing rules should not enable licensees to publish disingenuous statements not made in good faith, especially when the lives of the frail and elderly are at issue. It is never the appropriate time or place to silence best interests of most vulnerable to the benefit of those fearful of opportunities for improvement. This is a patent, constant issue within SNFs.