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Laguna Honda officials outline steps toward CMS recertification as discharge planning continues

San Francisco Health Commission · June 20, 2023

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Summary

Laguna Honda's interim CEO told the San Francisco Health Commission the nursing facility has filled key leadership posts, piloted a "consistent care at the bedside" program and reduced regulatory findings since a December survey, but said the hospital awaits the formal CMS written report before filing for recertification; some public commenters warned the facility remains at risk of closure before Sept. 19.

Laguna Honda's interim leadership told the San Francisco Health Commission on June 20 that the hospital is moving toward resubmission for a CMS recertification survey this summer after months of targeted staffing and process changes.

Roland Pickens, acting CEO for Laguna Honda, announced the selection of Sandra Simon as the facility's nursing home administrator and CEO, effective June 26, and said Greg Chase has been hired as director of facilities and engineering. Pickens said the department is still recruiting for director-of-nursing and medical director roles and expects remaining conditional offers to be finalized after background checks.

Pickens told commissioners that in November CMS terminated Laguna Honda's participation in the Medicare/Medicaid program and that a settlement agreement paused transfers to other skilled nursing facilities while allowing continued reimbursement. He said CMS directed the department to resume discharges only for residents who no longer require skilled nursing care. "Of the 42 residents identified in early April as no longer needing skilled nursing care, six have been discharged — one home and five to board-and-care facilities — leaving 39 people in that cohort as of today," Pickens said.

The presentation stressed operational changes intended to improve bedside care and regulatory compliance. Pickens described a pilot program called "consistent care at the bedside" (CCBM) that embeds director-of-nursing'level consultants on each of Laguna Honda's 13 nursing units to work "at the elbow" with nurse managers and staff, run daily huddles, escalate safety or compliance concerns within four or 24 hours depending on severity, and coach staff using adult-learning techniques. Pickens said the pilot began roughly three weeks earlier and has shown "tremendous improvements," and that the initiative will run at least through December.

On survey performance, Pickens reported the most recent 90-day CMS monitoring survey (June 5'9) yielded approximately 44 preliminary regulatory findings, down from the 120'to'140 findings cited during a full survey last December and the roughly 20 findings reported in an earlier abbreviated survey. He said the QIE (quality improvement expert) root cause analysis and action plan expanded to about 520 milestones; Pickens said the department has been completing successive milestones and receiving validation from a CMS quality improvement expert. "We are confident that is still going to be the case" for a summer resubmission, he said, but added the team is awaiting CMS's formal written report (which CMS guidance says should arrive within 10 business days) before finalizing a submission date.

Commissioners pressed for details on sustainability, org charts and the relationship between HSAG consultants and the CCBM staff. Pickens said the recertification application itself is ready and that the department plans to present a sustainability plan to the Laguna Honda Joint Conference Committee explaining how new hires, embedded monitors and consultants will coordinate long term.

Several public commenters urged caution and more transparency. Francisco de Costa alleged the needs assessment omitted causes of prior resident deaths and questioned consultant spending; another caller cautioned against cohorting behaviorally complex patients with elderly nursing-home residents and urged separate facilities or clearer separation. Pickens and commissioners repeatedly emphasized the city'wide shortage of skilled nursing beds and the need to avoid a loss of Laguna Honda capacity.

Next steps: Laguna Honda staff said they will wait for the formal CMS written findings, continue implementing and tracking CCBM and milestone work, provide a sustainability plan to the JCC and move ahead with the recertification submission process once the CMS documentation arrives.