PRSRT STDU.S. Postage

PAIDTallahassee, FLPermit No. 1007

A Long Term Care Monitor of Nursing Home and Assisted Living IssuesPulse

JANUARY 2004

FHCA

InsideNursing Homes-Nursing Schools . . 5Mold Mania! . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7Transfer/Discharge Update . . . . . . . 11Safe Food Prep.. . . . . . . . . . . . . . . . . . . . . . 12

FLORIDA HEALTH CARE ASSOCIATION

FHCA turns 50

The year 2004 marks FHCA’s50th year serving long term

care providers in Florida. From itsbeginnings as an informal affiliationamong Miami area nursing homes,to its present day status as the unitedvoice of all professional long termcaregivers, FHCA has worked tirelessly to improve the quality oflife of the elderly entrusted to itsmember facilities’ care.“We saluteall those who did and continue todo health care’s toughest job withjoy and dedication,” FHCAPresident Kelley Rice-Schild said.

Estern is sculptor

Last month’s FHCA Pulse inad-vertently omitted the name of

Neil Estern, the talented sculptorwho created the8' 2" bronze statueof former U.S. Rep.Claude Pepper thatstands outside thePepper Center inTallahassee. Mr.

Estern is a nationally recognizedartist whose commissioned worksinclude the FDR PresidentialMemorial in Washington, D.C.,Presidents John Kennedy andJimmy Carter, J. Edgar Hoover,Fiorello LaGuardia, J. Robert Taftand Princess Diana.

IO forum

The American Health CareAssociation’s 2004 Independent

Owner Leadership Forum isFebruary 9-10th in Las Vegas, Nevada.Attendees can earn up to 11 con-tact hours of continuing educationin topic areas that include thrivingin a challenging environment,

Update

Proof positive:Nursing home care better…two years in a rowFlorida regulators report quality improvement trend continues;no improvement in lawsuit, liability insurance situation

Florida Health Care AssociationP.O. Box 1459Tallahassee, FL32302-1459CONTINUED ON PAGE 11

Two years after landmark elder care legislationtook effect in 2002, a year-end report by the

Agency for Health Care Administration docu-ments steady, uninterrupted quality improvementamong the state’s nursing homes.The report alsoshows that despite nursing home lawsuit reformsapproved in May 2001, another 2,482 notices ofintent to litigate have since been filed, 95 percentof which are against nursing homes.

AHCA reports marked drops in the numberof both serious and non-serious compliance vio-

lations found during surveys, as well as significantdecreases in the number of citations issued forstaffing deficiencies. For example, of the 59 cita-tions issued in 2003 for insufficient staff, only 10percent of those also were cited for falling belowstate-required staff-to-patient ratios.

Liability insuranceUnfortunately, there does not appear to be

any let-up in the cost of facility liability insurance,which for some now exceeds $7,000 per bedannually. AHCA reported insurance coverageamounts, noting that among facilities reporting“general/professional” coverage, 37 percent car-ried coverage of $100,000 or less; among thosereporting “general/professional – per occurrence”coverage, 45 pecent carried coverage of $100,000or less; and among those reporting “general/pro-fessional – aggregate” coverage, 30 percent carriedcoverage of $50,000 or less.

Among some of the noteworthy items in thereport:■ Three lawsuits per day: Reported nursing

home liability claims for the 12-month periodending September 30, 2003 showed 975 claims,or an average 2.70 Florida claims per day.

■ For-profit vs. not-for-profit: Although thenumber of facilities reporting notices of intentto litigate is proportional to the number offor-profit and not-for-profit facilities, on a

Better Pain ManagementSee Page 6

Christmas visitor: FHCA Treasurer DeborahFranklin (in vest), District IV (Tampa) PresidentBen Carotenuto and Brandon Health & Rehabstaff greet Rep. Sandra Murman (R-Tampa),center, during a recent holiday visit. FHCAmember facilities have been hosting statelegislators in advance of the 2004 Floridalegislative session that begins in March. CONTINUED ON PAGE 3

Florida Health CareAssociation

Kelley Rice-Schild,President

Bill Phelan,Executive Director

Dion Sena,Senior Vice President

David Sylvester,Secretary

Deborah Franklin, Treasurer

FHCA PulseJANUARY 2004

FHCA Pulse is produced monthly for theFlorida Health Care Association, P.O. Box1459, Tallahassee, FL 32302-1459, by EdTowey & Associates, Inc.

Editorial – To submit information, guestarticles, press releases, etc., contact EdTowey at (850) 224-6242 or via e-mail atetowey@fhca.org. Fax information to (850) 224-9823 and include your name,telephone number and e-mail address.

Advertising – For information on Pulse ad-vertising rates and availabilities, contact IanCordes at Corecare Associates at (561) 659-5581 or via e-mail at icordes@bellsouth.net.

All articles and advertising are subject toeditorial review.

FHCA JANUARY 2004 Pulse2

FROM thePRESIDENT’S

DESK

by Kelley Rice-SchildFHCA President

This month begins the 50th year that the Florida Health Care Association has been represent-ing the nursing homes in our state. In 1954, Ike was president and midway through the first

of his two terms; Elvis was on the verge of being crowned “king,” and Dr. Jonas Salk was set tobegin inoculating schoolchildren with his newly-created polio vaccine.

In 1954, it would still be more than ten years before Congress would create the Medicare program, and later, Medicaid. There was almost no state regulation of nursing homes and no state-licensed nursing home administrators at all. In fact, the only governmental involvement in nursing homes were the local health departments that would send “county patients” to thefacilities and pay the facilities no more than a few dollars per day for their care.The few nursinghomes that existed in Florida at that time were “mom and pop” operations that were pretty muchon their own.

Reimbursement, fair regulationIt was in early 1954 that a small group of nursing home owners in Miami sat around a table

and decided to join forces for their collective betterment. Thus, the Florida Nursing HomeAssociation was born.Their goal was to remain at least one step ahead of the coming regulation,to improve quality care and to fight for increases in the governmental reimbursement necessaryfor improvement. Sound familiar?

It’s true that despite the many changes we’ve seen in Florida over the years — and particularlyin the elder care profession — some things never change, nor should they. For us, fighting for adequate reimbursement and even-handed regulation is our eternal legislative agenda becauseboth are the fundamental elements for improving care for the elderly we serve.

No plagiarismOne invaluable ingredient that has kept our association strong for 50 years is the active

sharing of knowledge among members. Shirley Schachter was one of the FHCA founders at that Miami table, and she gave me the best advice I ever got about nursing home operation.“If you see someone else who has a good idea, steal it,” Shirley said. “There is no such thing as plagiarism in nursing homes.Today we call this sharing ‘Best Practices,’” and FHCA’s QualityUnit devotes much of its time to finding ways to improve care and then shares these ideas withFHCA members. This includes conducting seminars around the state so that administrators,nurses and other caregivers can learn about the current issues and how to improve what we do.Also, informal information-sharing happens at monthly FHCA district meetings, where you canalways hear the latest survey experiences or recruit consultants.

As we celebrate our Golden Anniversary, let’s try to keep in mind why FHCA was started so that each of us may relive the enthusiasm and energy that was around that table 50 years ago.By joining forces and fighting for common goals, we may well find that our next 50 years arefiner than our first.

Thoughts on turning goldenOur core mission remains the same, even after 50 years

In addition to all FHCA members and associate members, FHCA Pulse is also mailed to

legislators, opinion leaders, reporters and state/federal regulators in Florida. The wider

distribution allows others to better understand long term care and the daily challenges

faced by the nursing homes and assisted living facilities we represent.

Note to Pulse readers

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We are dedicated to delivering quality, cost-effective pharmaceutical care with a commitment to customer-defined service and a focus on maintaining the highest standards of ethics, integrity and compliance.

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FHCA JANUARY 2004 Pulse 3

per-1,000-bed basis, for-profit facilitiesexperience a greater volume of NOIs on a per-bed basis (32.58 vs. 15.29).

■ Under-count: AHCA candidly admittedthe actual number of liability claims maybe greater than reported because post-change of ownership claims may not bereported by the previous owner.

■ Insurance premiums: Based on a sampleof 190 nursing homes’ Medicaid costreports, the average annual insurance pre-mium was $1,698 per nursing home bed.

■ Closing: Twenty-two nursing homeshave closed since July 2001, causing2,084 beds (2.6%) to be lost. Even witheight new facilities opened since May2001, there remains a net loss of 1,291beds, combined with another 939 bedsthat were approved prior to the morato-rium on new construction but are yet to be built.

■ Old: Some 45 percent of nursing homesparticipating in the Medicaid programare 20 years or older. Some 109 nursinghomes (17%) are in buildings 30 years or older.

Nursing home care better… two years in a rowCONTINUED FROM PAGE 1

Total Nursing Home Deficiencies Cited(Excluding Life-Safety and Physical Plant Issues)

2003(thru Sept.)

2002

2001

The report was prepared in response toquestions submitted by the legislature’s JointSelect Committee on Nursing Homes.Thepanel will prepare recommendations for the2004 legislative session.

■ Going great: The report notes majorsuccess with the popular Quality of CareMonitor Program and the Medicaid “Upor Out” program.

0 1000 2000 3000 4000 5000 6000 7000 8000

Number of Deficiencies

Year

FHCA JANUARY 2004 Pulse4

LTC LEGAL

ISSUES andTRENDS

by Karen GoldsmithGoldsmith, Grout

& LewisFHCA Legal Consultant

New year’s updateThe latest on four legal issues affecting you

This month, instead of focusing on just onetopic, let’s touch on four of the more pressing

legal concerns.

KickbackThe law is clear: It is a violation of the anti-

kickback statutes to receive anything of value inreturn for referring business to an individual orcompany. The “free diapers for your Medicaidpatients” sales pitch sounds too good to be true, andit is. While the vendor may make such an offer ifyou agree to order from him for your other patientswith other payor sources, accepting this offeramounts to a kickback. A violation of either thestate or federal anti-kickback statute can result inhefty fines and, worst of all, jail time.

But, you may say: “Who will know?”Well, thevendor who just lost your business may do a littlesnooping, and if he gets wind of the deal, may turnin his competitor. Ever hear of blackmail? Theoffice manager who is doing a poor job may havejust gotten herself some job security if she knows ofthe arrangement. And even if no one tells on you,other providers may have the same deal and some-one may blow the whistle on them.An investigationof the shady vendor may lead the investigators rightto your door.

Not all such “free supply” arrangements are illegal. Some are permitted. When you have anydoubts about the arrangement, or if it looks toogood to be true, have your attorney look at it.Sure beats calling your attorney from jail!

Advance directivesThe Terri Schiavo case continues to cause a stir

among us. Families are following the newspaperstories and questioning the legality of the decisionsthey are making for their own loved ones.Actually,the Schiavo case changes little or nothing in ourenvironment.The law passed last October to allowher feeding tube to be reinserted applied only toher and terminated by its own provisions.The lawas we have known it is still applicable to the averagepatient in your facility.

CMS discountWhile you are entitled to a 35 percent discount

on a federal civil money penalty, the discount is notautomatic.You must waive your right to a hearingin writing during the 60 days to appeal.Waiving yourright to a hearing does not mean that you are inagreement with the survey findings. Any waivermust clearly state that it is not an admission of thefacts or that the deficiency existed as cited. If you donot ask for the discount and waive your right in

writing, you will lose the discount. Pay attention to those dates.

Point of entryProviders continue to miss a point of entry

into the appeals process because they overlook thelanguage in communications from the Centers forMedicare & Medicaid Services and the Agency forHealth Care Administration.

If you receive an Administrative Complaint fromAHCA, it will tell you when and how to appeal.There will be a form attached to identify your posi-tion. Be careful before you pick Option #1, whichis an admission of the facts. If you make such anadmission and further sanctions are imposed becauseof the survey, the form may be used against you asan admission against interest. There is no legalrequirement that you use that form.A letter statingthat you are not challenging the deficiency but donot agree that it existed can be used in place of it.However, if you want a formal hearing, you mustprepare a petition that complies with Chapter 120,Florida Statutes. It’s best to have your lawyer do that.

You may also receive other communicationswhich trigger what is called a “point of entry”into the appeals process. An Intent to Issue aConditional License notice or similar documentcan trigger the time for appeal. Again, read thedocument carefully and be sure you do not inad-vertently waive any rights or create an admission.

If you get more than one document as a resultof a survey (i.e., an Administrative Complaint for afine or an Intent to Issue a Conditional Licensenotice), each must be appealed separately.They willlater be consolidated for hearing, but challengingone does not create a challenge to all. These aretime-sensitive and if you do not appeal timely, youwill most likely lose that right forever.

Watch the calendarAs to CMS, the primary trigger for appeal

rights is a letter from CMS reiterating the surveyfindings and giving you your appeal rights. Youhave 60 days to appeal or waive that right and geta discount (or do nothing and suffer the conse-quences).The ongoing survey process does not tollthis time.You most likely will not know the totalfine for several months. Just because you have notachieved substantial compliance does not meanthat your time is tolled. Often the petition is filedbefore the time has passed for determining if thefacility is subject to a denial of payment.

Here’s the bottom line: Read your mail andassume the dates in the correspondence are correctand binding.

The nursing home –nursing school connection

Partnership can be a win-win deal

by Lee Ann GriffinFHCA POLICY & QUALITYASSURANCE SPECIALIST

Previous issues of FHCA Pulse have highlighted some innovative Certified

Nursing Assistant and nursing-trainingcourses and programs, including the excitingCNA-to-LPN career ladder program currently underway in Ocala betweenTimberRidge Nursing and RehabilitationCenter and Central Florida CommunityCollege. These programs point up theimportance of good relationships amongcommunity colleges, vocational schools,private schools and long term care facilities.

According to a special report from theFlorida Board of Nursing, 11 new nursingprograms were approved in the past year,bringing an additional 500 slots for new students. For a local nursing home, theseprograms produce opportunities for part-nerships with the area schools.

Training siteNursing homes are particularly effective

settings for beginning undergraduate nursingstudents because they provide opportunitiesfor the student to practice a wide range ofnewly-learned nursing interventions. Forexample, appropriate objectives for instruc-tion in the nursing home could includecommunication skills, physical and psy-chosocial assessment, safety concerns, patienteducation and basic psychomotor skills.Students’ attitudes toward the elderly and theaging process can also be positively impact-ed by clinical placement in nursing homes.Another benefit is the built-in focus nursinghomes have toward creating homelike set-tings for their patients.This home-centeredmindset validates community health nursingtheory and provides an opportunity toexplore the links among individuals, familyand the community in patient assessments.

Right for you?If you’re considering such an arrange-

ment, here are some useful suggestions:■ Role models: Since licensed staff are serv-

ing as role models, make sure they demon-strate proper technique. Even experiencednurses sometimes cut corners, but this isespecially dangerous for new nurses whowill model their own practice on theexperienced role models around them

■ Professional behavior: Instructors andstudents are guests in the facility, so no

■ Tour: Offer a tour of the facility to newnursing studentsAlso, be sure the nursing program and

faculty have a philosophy compatible withyours (for example, an interest in providingage-appropriate care and the faculty’s atti-tude toward long term care).Are nursing stu-dents encouraged to consider a practice inlong term care after graduation? It’s also agood idea for you to view the exam resultsof different Florida LPN and RN nursingprograms to see how their graduates per-form. Go to the Department of Health’sBoard of Nursing Web site atwww.doh.state.fl.us and click on “Health CareProfessions,” then “Nursing,” then “Appli-cant Information,” then “NCLEX Results.”

Nursing schools considering partner-ships with nursing homes will be reviewingthe inspection results and staffing levels atthe federal Nursing Home Compare Website at www.medicare.gov. Nursing schools

unsolicited criticism. However, sinceFlorida is a mandatory reporting state,appropriate communications must occurif patient abuse or gross misconduct isobserved

■ Heads up: Make sure all staff (especially inthe reception area) know that nursing stu-dents are taking classes on particular days

■ Review: Provide a place for pre- andpost-class sessions for the class to con-vene for planning, discussion and review

■ Access: Agree on the level of access thestudents will have to the facility’s policiesand procedures, including safety procedures

■ Supplies: Make supplies a priority; lack oflinen and supplies compromise procedures

■ Save cost: Consider allowing students tosign up for the reduced-price lunchesemployees are offered

FHCA JANUARY 2004 Pulse 5

CONTINUED ON PAGE 9

FHCA JANUARY 2004 Pulse6

Guest Commentary

The many challengesof pain management

Having a sound pain management policy is a

good first step

by Howard Tuch, MD,

‘‘Pain” is defined as an unpleasant sensoryor emotional experience associated

with actual or potential tissue damage, ordescribed in terms of such damage.

Pain is extremely common and some-times under-recognized in nursing homepatients. The most common causes of painare due to musculoskeletal conditions(arthritis, fractures and wounds) but cancers,vascular problems, nerve damage (peripheralneuropathy, trigeminal neuralgia) and manyother conditions can cause significant painproblems. Chronic pain can take manyforms, ranging from clear physical and ver-bal expressions of pain to social withdrawal,weight loss, agitation and depression. Severechronic pain can even occur in the completeabsence of any outward signs of discomfort.Also, older people may deny having “pain”but say that they are “aching” or “stiff ” or“sore.” It is important to use many words ordescriptors when asking about pain.

Pain screeningAll patients should be screened for pain

upon admission in order to determine theirrisk for having unrecognized or unmanagedpain. During the admission assessment, thepatient/family should be asked about a his-tory of pain problems, history of stoicism orunwillingness to complain of pain, reactionsto pain medication and the impact of painon their life (on function, sleep, appetite,mood, mobility, rehabilitation efforts, social-ization, etc.).

For patients not complaining of pain,there should be a completion of the MDSassessment (J2a, b; J3) upon admission, thenquarterly, annually and when significantchanges occur to ensure ongoing painscreening. Screening for pain should involvequestioning the patient and caregivers aboutdiscomfort, observing the patient duringactivities (especially during potentially

Quality improvement strategies■ Develop a mission statement declaring

the right of the patient to have his/herpain assessed and treated and the com-mitment of the facility to manage pain.

■ Perform an audit of pain and its man-agement in your facility to determinethe extent of the problem and source ofbarriers to effective pain management.

■ In-service training for all new staff onthe facility pain management policy and commitment. Periodic in-servicetraining for all staff on principles of pain management and facility policy.

■ Educate patients and families about paintreatment and its side effects, dispellingmyths and reinforcing the need to reportsymptoms and develop shared goals.

■ Incorporate pain management intomonthly quality improvement meetings:monitor for consistent assessments; use of pain intensity scales;

CNA observation entries; care plandevelopment; communication with physi-cians; appropriate use of medications titratedto achieve comfort and patient goals; inter-disciplinary approaches used; and modifica-tions of interventions based on patientresponse.

■ Monitor the pain quality measure on thewww.medicare.gov Web site for both shortterm and long term patients.

AHCA survey citations for pain man-agement are on the rise.The FHCA trainingaround the state this month and next willhelp define the parameters of an effectiveapproach in your facilities. There are manyways in which a facility can develop andimplement effective pain managementstrategies.The FHCA Web site now includesa more detailed policy guide on pain man-agement as well as AHCA “Guidelines forPain 2002” for the surveyors.

(Dr.Tuch is FHCA physician consultant andMedical Director Long Term Care, Hospice ofSouthWest Florida.He also serves on the FHCAQuality Credentialing Foundation Board ofDirectors.)

painful procedures, dressing changes, etc.)and noting the use of and response to medications administered for pain. Thosepatients complaining of pain should under-go a complete pain assessment. Their painshould be followed using a standard painassessment tool.

The MDS fields on pain are completedusing the reported level of discomfort during the assessment period. For example, apatient who reports mild pain in the lastseven days should be reported as having“mild” pain (J2b=1), even if the patient isbeing given strong pain medication for priorcomplaints of severe pain. Clinical docu-mentation elsewhere in the record shouldsupport the use of the strong medication andthe fact that pain is now being effectivelymanaged.

Advertise in FHCA Pulsecontact Ian Cordes at Corecare Associates, exclusive sales agent

ph: (561) 659-5581 • fax: (561) 659-1291e-mail: icordes@bellsouth.net.

Pain management goals

■ Pain prevention, prompt recog-nition and assessment of painwhen present

■ Improved well-being and qualityof life for the patient in pain

■ Maintaining highest level offunctioning through effectivepain treatment

■ Establishing an optimum balancebetween pain relief on the onehand, and tolerable side effectsand function on the other

Mold mania by Max Hauth

Mold-related citations andlawsuits are on the rise

FHCA JANUARY 2004 Pulse 7

www.fhca.org

F H C A

Web siteWeb site• NEWS, BULLETINS• MEMBERSHIP• REGULATORY• REIMBURSEMENT

This past year the number of facilitiesreceiving citations on their environ-

ment seems to be on the increase. Thesecites center on something that is all aroundus — a fungus called mold.There are morethan 100,000 species of mold, and whilemost types are not hazardous to healthyindividuals, prolonged exposure may causeor exacerbate asthma or other allergies.

Hysteria over mold has also increased in the past year. By some estimates, about9,000 mold cases have been filed to date and insurers are running scared. Plaintiffs’attorneys continue to bring both propertydamage and personal injury claims, eventhough science has not established a cause-and-effect link between toxicity in humansand exposure to airborne mold. It is allegedthat children are particularly susceptible tomold because their immune systems aredeveloping, and so are those immune sys-tems already impacted by other diseases orconditions. Common symptoms that plain-tiffs claim as the results from the exposure tomold are aggravation of asthma, a runnynose, itching, burning, headaches, dizziness,cough, skin irritation and the inability toconcentrate.

the use of a bleach and water solution.Where more than 10 sq. ft. of visible growthis present, the guidelines recommend the use of personal protective equipment andthe contained area be under negative airpressure. For more information on the EPAguidelines, consult the EPA Web site atwww.epa.gov.

(Max Hauth is President, Hauth HealthCare Consultants, Lakeland, and a frequent con-tributor to FHCA Pulse on life safety issues.Contact him at (863) 688-0863.)

Causes of moldMold problems can occur when im-

proper construction or failed maintenanceallows water intrusion or a chronic moistureproblem to exist in a building. Molds need a moist environment, oxygen, and organicmaterial on which to establish and grow.Most need a temperature range of 60 to 90degrees F. Causes for mold include buildingswith leaking roofs, windows, plumbing, airconditioners that are not providing adequatedehumidified air and exterior walls that are not sealed properly or where venial wallcoverings were used.

CleanupProper procedures need to be taken

when treating an area where mold is pres-ent. When disturbed, the mold spores maybecome airborne and affect other non-contaminated areas. The EnvironmentalProtection Administration recommends thatif there is less than ten square feet of visiblegrowth, cleanup can be accomplished by

FHCA JANUARY 2004 Pulse8

LTCBUSINESSNEWS

by Steven R. Jones, CPAand Dawn Segler, CPAMoore Stephens LovelaceFHCA CPA Consultantwww.ms-lovelace.com

Last month, President George W. Bush signedinto law the Medicare Prescription Drug,

Improvement and Modernization Act of 2003,which established a Medicare drug benefit to takeeffect in 2006. It is being hailed as the most signif-icant piece of Medicare legislation in 40 years.

In addition to the new prescription drug bene-fit, the bill also contains a number of provisionsimpacting on skilled nursing facilities. With thesigning of the bill into law, the Part B therapy capwas immediately lifted for the remainder of 2003and a two-year moratorium went into effect for2004 and 2005.

Skilled nursing facilities will also benefit in theimplementation of an AIDS adjustment to the PartA PPS rates. Base federal rates, without regard toother add-ons currently in place, are increased 128percent in order to reimburse facilities for the addi-tional costs incurred in caring for patients withAIDS. This provision is effective for services ren-dered on or after October 1, 2004 and will sunsetwhen the RUG system is revamped to includethese costs.The physician fee schedules, which areused in establishing payments for Part B services,will receive an increase of 1.5 percent, as opposedto the 4.5 percent reduction in payments originallyslated to go into effect January 1, 2004. An updateof 1.5 percent was also mandated for the 2005physician fee schedules.

Medicare recoupment actionsAs we previously reported, the U.S. Department

of Health and Human Services Office of theInspector General issued a series of reports in 2003resulting from a nationwide audit of SNF Medicareclaims. The OIG reported finding deficiencies inthe systems used to verify that Part A claims wereindeed preceded by the required three-day qualify-ing hospital stay. By the OIG’s estimate, SNF over-payments exceeded some $200 million. As a resultof the original findings, fiscal intermediaries hadagreed to assist the OIG in the investigation of theseclaims and to initiate recovery efforts. In a memodated November 26, 2003, the OIG and CMS haveinstructed the FIs not to pursue collection of these“overpayments” and to return any payments alreadyrecouped as a result of these audits. CMS stated inthe memo that though the audit findings raised “sig-nificant policy issues” with respect to eligibility cri-teria for SNF care, they did not find any “deliberatepattern of misrepresentation” that the provider com-munity was at fault for the identified overpayments.

Medicaid cost reportingIf you haven’t received it already, you should be

receiving the Medicaid electronic cost reportingsoftware developed in-house by the Agency for

Health Care Administration. Effective for costreporting year ends on or after December 31, 2003,cost reports must be submitted electronically.Providers can use other software, as long as data is exported into a specifically formatted file fortransmission to AHCA. AHCA will offer trainingsessions in the near future. Changes to the filingdeadlines may also be on the horizon. The draft of the next version of the reimbursement plan proposes a five-month filing deadline (instead of the current three months) for periods ending on or after June 30, 2004. However, cost reports will have to be received (meaning in AHCA’shands) by April 30th or October 31st to be used inthe July or January rate-setting starting with theJanuary 2005 rate semester.

Unfunded wage increaseWith Florida facing an estimated $1.4 billion

deficit, the upcoming legislative session is expectedto be at least as challenging as last year’s. One badpiece of legislation that has already resurfaced is SB274, which reintroduces the $1 per hour increase inwages for all hourly nursing home employees.Thisbill differs from the prior year’s in some key areas:■ The mandate would also apply to nursing home

employees provided by a leasing company.Leasing companies were exempted from lastyear’s version.

■ The 2004 version of the bill would exemptthose facilities which offer health insurance benefits to all staff, which covers employees anddependents, and the employer contributes atleast 80% of the total insurance premium (isthere really someone who can afford this?).Thebill states that although the costs will be consid-ered allowable for cost-reporting purposes,providers will not be eligible to receive interimrate to cover the additional cost.

■ If passed, the one-time increase could not belater rescinded by the nursing home operator,future operator, management company or staffleasing entity.

The nursing homes have always said that anynew mandates must be fully funded, but SB 274makes no mention of where the money wouldcome from to pay these huge wage increases. Also,some legislators already are concerned over thedangerous precedent such a bill would set. Lastmonth’s FHCA Pulse carried an interview withSen. Evelyn Lynn (R-Ormond Beach) who said,“I don’t believe the state should be mandating what private businesses or not-for-profits pay theirworkers...There’s a marketplace that takes care ofthat, and from what I’ve seen in terms of nursingassistant wage increases, it seems to be working.”

Nursing homepatients and facilitieswill benefit from thatnew Medicare bill

Some good news for the new year

FHCA JANUARY 2004 Pulse 9

Three reasons whyI’m an FHCA member

For FHCA membership information, contact Leah Martineau at (800) 771-3422

or via e-mail, lmartineau@fhca.org.

Have you ever asked yourself why you’re a memberof something? If you ask me why I’m an activeFHCA member, I’ll give you three good reasons:

1.Being an FHCA member helps me rememberthat I am not alone with LTC problems and

issues and that I am a part of the overall long termhealth care team. It’s really a good perspective-restorer to know there are other people in Floridalike me who have the same concerns and havesuccessfully found answers to the very problems I might be having in my own facility.

2.FHCA membership helps me stay betterinformed. It helps make me a stronger pro-

fessional, which in turn helps me create a betterfuture for the people I serve.

3.Being an FHCA member gives me a safeplace to try out a theory, work on a solution

or just share ideas with colleagues. The more Iinvest, the greater the rewards have been!

Robin BleierRB Health Partners, Inc.robinbleier@yahoo.com

FHCA WelcomesNew Members

)ASSOCIATE MEMBERS

Staples, Oviedo

Quintairos Prieto Wood & Boyer, P.A.,Tallahassee

Genesis Business Solutions, Newnan, GA

will also be looking at the facility’s location,philosophy and the availability of role models at the facility.

Nursing homes make great settings forproviding nursing students with training inholistic and individualized care. Nursingschools work to provide an adequate supplyof well-trained practical and professionalnurses.

(Special thanks to Judy Thom,Learey TechnicalCenter in Tampa, and Lois Gackenheimer,Academy for Practical Nursing in West PalmBeach, for their help in preparing this article.)

Nursing home –nursingschool connectionCONTINUED FROM PAGE 5

FHCA JANUARY 2004 Pulse10

employee or ask the employee to submit to a medical examination. Such follow up should bereserved for situations where the employer has agood faith belief that the employee’s medical condition may be the cause of his or her inabilityto perform. The employer also may require theemployee in such situations to provide a doctor’snote for any sick or other leave that the employeewants to take and that it is safe for the employee toreturn to work, assuming that such procedures areapplied to all employees who request sick or otherleave. Medical inquiries also are permitted whenthe employee has requested a reasonable accom-modation or to allow the employer to comply withother obligations it may have such as providingbenefits under Workers’ Compensation law.

Protecting confidentialityConfidentiality of medical information is a

central provision of the ADA and employers mustrespect an applicant or employee’s right to privacy,except as specifically allowed by law. For example,in the fact sheet, the EEOC notes that an employ-er cannot inform co-workers that an employee has diabetes or that the employee is receiving anaccommodation because he or she has diabetes.Instead, the EEOC suggests that the employerexplain to co-workers the need to respect privacyand that it has adopted a policy to confidentiallyassist workers who are experiencing difficulty inthe workplace. It further suggests that an inquiringparty could be told that “her privacy similarlywould be respected if she ever had to ask theemployer for some kind of workplace change forpersonal reasons.” The EEOC also notes thatemployees will benefit from having general information on the employer’s policies on accom-modation and that “this kind of proactive approachmay lead to fewer questions from employees whomisperceive co-worker accommodations as ‘specialtreatment.’”

Various types of accommodations may be rea-sonable for an employee with diabetes. Amongthose noted by the EEOC are:

■ providing a private area to test blood sugar levels or to take insulin,

■ providing a place to rest until blood sugar levels stabilize,

■ providing breaks to allow the employee to eat, drink, take medication, or test blood sugarlevels,

■ leave for treatment or recuperation,■ and modified work schedules.

In this month’s column, we discuss a new factsheet issued recently by the U.S. Equal Employ-

ment Opportunity Commission on diabetes in theworkplace, which includes questions and answerson frequently addressed issues which arise underthe Americans with Disabilities Act. The fact sheet notes that nearly 17 million adult Americanssuffer from diabetes, so these issues affect a sub-stantial portion of the population and are likely to come up in the workplace. In addition, theanalysis contained in the fact sheet would apply to almost any disability under the ADA and can bea source of guidance with regard to disabilitiesother than diabetes.

Proper inquiriesThe first issue addressed by the fact sheet is the

degree to which an employer can inquire aboutthe employee’s medical condition. Before a condi-tional offer of hire has been extended to an appli-cant, the employer may not inquire as to whetherthe employee has or may have a disability.However, if the applicant voluntarily discloses thathe or she has diabetes, the EEOC states that theemployer can ask only two further questions:whether the applicant needs a reasonable accom-modation and what type of accommodation. Atthis stage, the employer would not be able to askquestions about the condition, such as how longthe applicant has had diabetes or whether theapplicant takes medication to control it.

Once the applicant is conditionally hired (butbefore he or she has commenced work), theemployer has greater leeway in asking about theapplicant’s condition. For example, the employermay ask follow-up questions such as whether theapplicant takes medication, whether the conditionis under control, and how long the applicant hashad diabetes. In addition, the employer may requirethe applicant to submit to a medical examination,so long as other applicants in the same job catego-ry also must do so. If the employer withdraws a joboffer based on information obtained during thisperiod, it must be able to show that the applicantis not able to perform the essential functions of the job, with or without reasonable accommoda-tion, or that the applicant is a direct threat to theapplicant or others in the workplace.

Once an employee has joined the workforce,the number of inquiries an employer can makeagain narrows. However, an employer who has alegitimate reason to believe, based on objectiveevidence and not merely speculation, that anemployee may not be able to effectively or safelyperform his or her job duties, may inquire of the

LABORRELATIONS

COUNSEL

by Mike MillerKunkel, Miller & Hament

FHCA Labor RelationsConsultant

CONTINUED ON PAGE 12

Diabetes in the workplace and the ADAA new fact sheet spells out the do’s and don’ts

FHCA JANUARY 2004 Pulse 11

Another look attransfer-discharge

by Peggy RigsbyFHCA GOVERNMENT SERVICES DIRECTOR

Both federal and state law spell out the

circumstances underwhich you may move

a patient

We continue to get lots of questionsabout patient transfer and discharge,

so let’s go through the federal and statebasics.

FederalPart 42, Code of Federal Regulations,

Section 483.12, sets forth the federalrequirements on transfer and discharge.These requirements apply to transfers or discharges that are initiated by the facility,not by the patient. Moving a patient from a certified area to a non-certified area isconsidered a transfer. Moving a patient to a non-institutional setting is considered adischarge.

Federal law allows transfers and dis-charges only for any of six specific reasons.Moving a patient for any other reason is notallowed, and will, at the very least, result in a deficiency citation.The six reasons:1. Necessary to meet the patient’s welfare

which cannot be met in the facility.2. Patient’s health has improved and no

longer needs facility services.3. Safety of individuals in the facility is

endangered.4. Health of individuals in the facility is

endangered.5.After sufficient notice, patient refuses to

pay for services.6. Facility ceases to operate.

Reasons #1-5 require documentation in the patient’s clinical record. Reasons #1and #2 require documentation by thepatient’s physician, and reason #4 requiresdocumentation by any physician. Reason#5 would require documentation ofattempts to obtain payment.

The federal interpretive guidelinesdescribe the required 30-day notice andstate that Medicaid patients must receivenotice of the facility bed-hold policy priorto transfer for hospitalization or therapeuticleave. This notice must also be given to the patient’s family or representative. Alsoimportant is that a patient cannot be transferred for non-payment if a bill hasbeen submitted to a third party, such asMedicaid, unless the claim has been deniedand the patient has refused to pay.

StateChapter 400.0255, Florida Statutes,

outlines the state law on transfer and dis-

charge. Similar to the federal law, this statutealso contains requirements on proper noticeand fair-hearing provisions. For certifiedfacilities, both laws must be considered atthe same time as a decision is being made on the appropriateness of any transfer or discharge.

Here’s a frequent question we receive:May a facility discharge a patient who hasbeen Medicare-eligible, Medicare benefitshave stopped and the patient is now poten-tially Medicaid-eligible but the patient’s current bed is not certified for Medicaid and there are no Medicaid-certified bedsavailable? Over the past few years, mostfacilities have Medicaid-certified their entirebuilding so they are not faced with thisdilemma, but there are still facilities withspecific certified areas, and as such, thesefacilities may not have an empty Medicaid-certified bed to accommodate this patient.Regardless of the amount of “up front”notice that may have been given to thepatient and family by the facility, dischargedue to”“Medicare termination,” or “noMedicaid-certified bed available” is animproper discharge, and the facility will be cited for a deficiency by the Agency for Health Care Administration.

Bed-count changes“Wait,” you may say. “Federal law limits

changes to my Medicaid-certified bed countto only twice a cost reporting year, and if it’s already been done twice this year, then I cannot add more beds and I cannotaccommodate this patient.”

Answer: You can get an exception to the twice-a-year change limitation by sub-mitting an exception request to the head-quarters Medicaid office, and if you submitthe proper paperwork, it will probably beapproved. True, Medicaid will frown a bitupon your request and may even suggest to you that you should have planned aheadfor such emergencies, but you’ll likely getthe okay.

Some facility people I’ve talked withhave suggested that if the Medicaid bed certification is denied, or if it’s not submit-ted, the patient can be charged the facility’sprivate-pay rate, and if not paid, can be discharged for non-payment (which is oneof the six allowable reasons). The problemwith this alternative is that the patient has a payor source, but the facility refuses to doits share of the responsibilities to accommo-date this alternative.

Un-waivable rightSome facilities are advising their

Medicare admissions that they will be dis-charged when their Medicare benefits areexhausted. ’This is not an acceptable practice andyou will be cited by AHCA if and when thisoccurs.

To be absolutely certain, I double-checked with the AHCA headquarters staffin its Long Term Care Unit. In fact,AHCA reminded me, the language in Ch. 400.022(p)

F.S., gives patients the right to be “trans-ferred or discharged only for medical reasons or for the welfare of other residents.”It goes on to state that a facility may not“transfer or discharge a resident solelybecause the source of payment for carechanges,” and that such waivers of this right are”“void and unenforceable.” The best advice I can give is to plan ahead and to screen all your admissions very carefully.

insurance “captives,” arbitration agree-ments and legal issues.There are reducedregistration fees if you register beforeJanuary 28th. For information, go towww.ahca.org and click on “Events.”

RNs or LPNs

Clarification: Florida law and rule currently does not require nursing

homes to have licensed nurses present inthe dining room, but good risk manage-ment practice includes having either RNs or LPNs on duty in the dining room to ensure nutritional needs arebeing met and to perform emergencyprocedures, if necessary.

CONTINUED FROM PAGE 1Update

FHCA JANUARY 2004 Pulse12

‘‘Food sanitary condition,” F371, hasalready become this year’s most often-

cited deficiency — again. Among Florida’snursing homes that were surveyed betweenJanuary and September 2003, approximately41 percent were cited under F371.The threemajor compliance issues were presented atrecent AHCA-FHCA training to reduceyour facility’s chance of being cited underthe F371 tag.

Temperature-time controlFacilities are being cited for their freezer

temperatures being above °F, expired food,undated refrigerated food and improperholding temperatures for both hot and coldfoods.You can avoid this by:

■ Keeping potentially hazardous foodabove or below the “Food DangerZone” (from 41°F to 140°F)

■ Within 7-10 days, consuming or discard-ing date-marked ready-to-eat, potentiallyhazardous foods held at 41°F

■ Establishing and maintaining a tempera-ture monitoring system, with monitor-ing records showing entries of at leasttwice daily and routine inspection of allthermometers at least weekly

■ Developing a system for dating refriger-ated foods and training employees onusing the system

■ Minimizing the time between hot foodpreparation and serving the food.

Contamination protectionFacilities are being cited for employees

handling ready-to-eat food with unwashedand/or bare hands, inappropriate storage ofraw, packaged and dry food, black moldgrowth on food containers and rusted metalkitchen equipment.Avoid a citation by:

■ Training employees in appropriate hand-washing practice and good personalhygiene, minimizing bare hand contactwith food (no bare hand contact withready-to-eat food), and effective preven-tion of sneezing, coughing, smoking, eat-ing and chewing in the kitchen area

■ Keeping appropriate separation betweenraw foods and ready-to-eat foods in thestorage area

■ Storing food six inches off the floor and away from the wall, ventilationopenings and unprotected water andsewer lines

■ Inspecting regularly for rusted or kitchen equipment or cookware in need of replacement, such as a can opener or a cutting board.

Warewashing, equipment sanitation

The number of citations issued forimproper water temperatures and equip-ment sanitations has been trending up inrecent years. Citations are being given forminimum wash and rinse temperature,chipped surfaces, worn parts and for infre-quent cleaning of mechanical ware-washingequipment. Both the FDA Food Code andthe Florida Administrative Code requirespecific standards for water temperature, san-itizer concentration and cleaning proceduresfor various types of mechanical equipment.Avoid the citation by:

■ Setting an appropriate temperature,washing duration/cycle for every pieceof mechanical equipment, according to the manufacturer’s specification.Water should be at least 160°F

■ Maintaining temperature logs for monitoring washing cycles and sanitizerconcentration in automatic dishwashingmachines

■ Training employees about minimumtemperature settings, sanitizer concentra-tion, how to test the machine/sink andreporting any unusual operation

■ Ensuring the clean equipment and uten-sils are stored at least six inches off thefloor and away from the wall, ventilationopenings and unprotected water andsewer lines

■ Periodically checking for dripping con-densation from ceiling vents fallingon/near equipment and food

■ Inspecting all equipment regularly forany unusual or improper operation and

removing any equipment with chips,stains, rust, or any other damage thatcannot be adequately cleaned and sanitized.

(Editor’s note: For more on the subject, seeOctober 2003 FHCA Pulse, available atwww.fhca.org. Click on “Members Only,” then“Pulse Archive.”)

For example, the EEOC notes that foran employee who needs several breaksthroughout the day at a workplace whichordinarily does not provide them, assumingno undue hardship on the employer, “theemployer could accommodate the employeeby allowing him to take two 15-minutebreaks each day and letting him make up thetime by coming to work 15 minutes earlierand staying 15 minutes later.” An employercan ask for documentation from theemployee to support an accommodationrequest; it does not have to take the employ-ee’s word for it. Also, an employer is notobligated to provide the accommodationrequested by the employee, so long as a rea-sonable accommodation is offered.

More information and a copy of the full text of this fact sheet can be obtainedfrom the EEOC’s Web site at www.eeoc.gov/facts/diabetes.html.

Labor Relations CounselCONTINUED FROM PAGE 10

Preparing food safelyby KoKo OkanoFHCA HEALTH SERVICESRESEARCH ANALYST

Steps you can take to avoid being cited

Food safety resources

■ FDA Food Code at www.fda.gov

■ National Food Safety Programsat www.foodsafety.gov

■ “Best Practices for Complianceto Food Sanitary Conditions in Florida Skilled NursingFacilities” at www.fhca.org.Click on “Members Only,”then “Quality Improvement,”then “Risk Management andQuality Assurance.”

FHCA JANUARY 2004 Pulse 13

Firing the administratorafter a bad survey isn’t

the way to go

Reducing turnover invests in LTC future

by LuMarie Polivka-WestFHCA POLICY AND QUALITYASSURANCE DIRECTOR

Owners and managers of nursing homesin Florida are being encouraged

through the FHCA Quality CredentialingFoundation to rein in staff turnover rates byinvesting in making their facility a betterplace to work. Recently, FHCA submitted agrant proposal to the U.S. Department ofHealth and Human Services to improve theretention rates of nurses by improving jobsatisfaction and patient care delivery systemsin long term care facilities.We are planningto target ten facilities in the Tampa area iffunding is awarded for the grant beginningin the summer of 2004.The proposed proj-ect will look at the many factors that affectthe recruitment and retention of nurses.

StrategiesTo improve the workplace environment,

the project recommends strategies such asimproving communication among adminis-trators, nurses and direct-care workers, train-ing supervisory nurses to be more effectivemanagers and using role-modeling, mentor-ing and coaching to disseminate new infor-mation and skills.Research indicates that theleadership behaviors of administrators andnurse managers influence job satisfactionand retention of nurses, and are linked withjob satisfaction, staff turnover and quality-of-care outcomes.

FHCA’s Quality Credentialing Foun-dation has long recognized the importanceof sustained, quality staff interventions andcommunication as a cornerstone of access to quality care for nursing home patients.We have heard many times from our FamilyForum members that their family membersin nursing homes really grow emotionallyattached to administrative and direct carestaff.Among the patients is a genuine feelingof loss when there is turnover in the facility.

Sadly, we have heard time and again thatone of the negative outcomes of a “bad”survey is the replacement of the administra-tor, which is also often followed by theturnover of the Director of Nursing andother staff. Many times these decisions aremade in the immediate aftermath of a difficult survey, when the facility mayalready be in turmoil and professional staffare concerned about their own professionallicenses as well as ensuring regulatory compliance. Some NHA turnover is linkedto the owner’s belief that such a manage-ment change will favorably impress regula-

turnover with survey outcomes over time by geographic area.We will be sending out a survey in the coming months to supportthe analysis.

Turnover costsOther research indicates that staff turn-

over is generally recognized as an importantand costly factor:■ The financial costs of recruitment,

selection, repeated training and increasedneed for supervision

■ The emotional cost to staff from poorlyintegrated, low performing, and con-stantly changing personnel

■ The “quality” cost to patients fromuneven standards of care and repeatedbreaking of staff-patient relationshipsGiven our current climate of scarce re-

sources, the more complex patient caredemands and the increased workloads requirethat creative retention strategies be explored.The FHCA Quality Credentialing Foun-dation plans to do just that in the coming year.

tors who are considering facility sanctionsfollowing such a survey.

Why geographic variance?But wait just a moment.A closer look at

the survey process outcomes by geographicarea indicates that administrative staff may be more “at risk” of replacement if theywork in facilities surveyed by the Agency for Health Care Administration’s area officesin Orlando, Ft. Myers, Palm Beach andPensacola because 70 percent of the facilitiesin AHCA’s lowest 15 percent ranking arelocated in those survey areas. The flip side of that same review finds that 72 percent ofthe facilities in the top 15 percent of theAHCA ranking are in the areas surveyed out of the Gainesville, Jacksonville, and theTampa Bay AHCA area offices. It will beinteresting to study the alignment of staff

FHCA JANUARY 2004 Pulse14

American Health Care Association and National Center for Assisted LivingAHCA/NCAL offer hundreds of long term care professional development resources. Categories include Care Practice,Compliance & Regulation, Staffing & Retention, Consumer Resources, Nurse Aid Training, Assisted Living and manymore. Go to www.ahca.org/store/index.html or call (800) 321-0343 Monday - Friday, 9 am - 6 pm to place an order.

BenTrust Benefit Solutions, LLCBenTrust Benefit Solutions, LLC, offers health insurance benefit plans to FHCA members. The plans designed especially for FHCA are an affordable alternative to the escalating costs of major medical plans and include cover-age for physician office visits, hospitalization, surgical services, drug benefits, dental, vision and much more. Nopre-existing conditions stipulations, guaranteed issue, and no deductibles. Improve employee recruitment andretention, enable all employees the ability to afford coverage and reduce facility overhead. Contact Frank J.Carreras, President/CEO, at (866) 335-8787.

Direct Capital Access, LLCA national mortgage company providing financing solutions tailored to health care businesses from coast to coast.We provide custom financing structures, HUD, Bridge, Bonds (taxable and tax-exempt), including Cash Out andNon-Recourse programs. Our experience, combined with creativity, consistently has produced solutions to operators’needs. How does a low, 7%, 35-year fixed rate sound? Call Scott A. Baldwin, Managing Director, at (800) 366-0443.

Edge Information Management Inc.Since becoming an approved service corporation company for FHCA in 1993, Edge has helped over 250 FHCAmembers meet their background screening requirements and kept them informed of pertinent legislative issues.Edge offers a variety of background checks including: drug screening, fingerprints, criminal, sexual offender,license verifications and references. Call (800) 725-3343.

FMS Purchasing & ServicesFMS has a full line of products and services in its Group Purchasing Program. FMS services member needs by ensuringmaximum savings and service. Five area managers throughout the state assure members an immediate response. Our services include: audits, a toll-free number, cost analysis, service reports and the Manufacturers Value IncentiveProgram. Call (800) 456-2025.

Heaton Resources (a division of MED-PASS, Inc.)Heaton Resources is a nationally known company specializing in the research and development of policy andprocedures manuals, regulatory guides and in-service training programs for the long-term care professional.Heaton products are comprehensive, easy-to-use and continuously updated. Our cross-referencing makes findinginformation easy. Call (800) 438-8884.

Office DepotOffice Depot offers Florida Health Care Association members extra discounts and services due to the cooperative purchasing power of FHCA. We offer a wide variety of benefits, including 167 items which have been reduced basedon volume ordering up to 80 percent off the list prices (the “High Use Item List”); next- day delivery on any amount ofproducts (no minimum order); an award-winning Web site which links you to your pricing and into the warehouseand keeps two years of tracking information at your fingertips. Call (800) 422-2654 for information or to set up anaccount; call (800) 386-0226 to place an order.

Prestige Printing & DesignPrestige Printing & Design has been involved in the long-term care printing and publishing business for the past 13 years. We provide both state and federal regulations and manuals, comprehensive resident rights and advancedirective programs, as well as standardized documentation forms for all phases of long-term care. We also handle fullcommercial printing & graphic design work. Call (800) 749-6773.

Senior CrimestoppersThe Senior Crimestoppers program is a proven, effective, proactive crime prevention system that combinesproven components to help provide safe, crime-free facilities for patients, staff, visitors and vendors. Personallock boxes for use by residents and/or family members, an around-the-clock, completely anonymous “tip line”call center, cash rewards of up to $1,000 posted on any and all incidents that occur and educational materialsfor residents, families, management and staff members are a few of the components that make up the program.More details can be found at www.seniorcrimestoppers.org or contact Donna Derryberry at (800) 529-9096.

Staffing Concepts of Florida, Inc.Staffing Concepts of Florida, Inc. is a professional employer organization which provides a comprehensive solution toyour personnel needs, including: employee benefits; workers compensation and safety programs; human resourcessupport; and payroll. SCI specializes in helping health care facilities better manage their single largest cost— labor. Call (800) 932-4610.

FHCA SERVICE CORPORATION SAVES YOU MONEY

We are proud to recommend these fine vendors who provide quality goods and services. They help keep you and FHCA on top!

FHCA Calendar of EventsPrograms marked with an asterisk (*) have registration brochures available via FHCA Fax-on-Demand at (850) 894-6299

and also are available at www. fhca.org. Click on “Seminars/Events.”

CLASS I F I EDSTurnaround Specialist. Available statewide. Aseasoned professional who has both manage-ment and consulting experience in the opera-tion of health care facilities. You will get both a license and an opportunity to “fine tune” the operation. Contact Doug Eitel at (813) 991-7400 or e-mail dreitel1@aol.com.

(“Help wanted” and “situations wanted” classifiedads are free to FHCA members. You can also postyour ad on the FHCA website at www.fhca.org.Click on “employment.”)

J A N UA RY

Thursday, January 8FHCA Professional Development

Committee meeting10:00 a.m. - 3:00 p.m.

Tampa Airport Marriott inside the Tampa International Airport

Friday, January 9FHCA Annual Conference

Committee meeting10:30 a.m. - 3:00 p.m.

Crowne Plaza Tampa – Westshore700 N. Westshore Blvd., Tampa, 33609

Tuesday, January 13*FHCA CNA

Train-the-Trainer SessionRegistration 8:00 a.m.; Session 8:30 a.m. - 3:30 p.m.

Manor At Carpenter’s, 1001 Carpenter’s Way,Lakeland, 33809

Call (863) 858-3847 for directions onlyRegistration for FHCA member facilities only.

Registration fee $150 per FHCA member facility participant. Registration fee includes CNA Test PrepCourse Instructor’s Guide plus five contact hours for

nurses. Registration limited to 25 participants per site.

Wednesday, January 14FHCA Associate Member Support

Committee meeting10:30 a.m. - 3:30 p.m.

Tampa Airport Marriott, inside the Tampa International Airport

Friday, January 16FHCA Steering Committee

meeting9:30 a.m. - 1:00 p.m.

Tampa Airport Marriott, inside the Tampa International Airport

*FHCA seminar: “Managing theUncertainties of Regulatory

Compliance in a RiskyHealth Care Environment”

Registration 7:30-8:30 a.m.;Program 8:30 a.m. - 4:00 p.m.

Tuesday 20 ......................................Holiday Inn Select316 W. Tennessee Street, Tallahassee, 32301

Call (850) 222-9555 or (800) 648-6135 for room reservations

Wednesday 21 ....................Tampa Marriott Westshore1001 N. Westshore Blvd., Tampa, 33607

Call (813) 287-2555 for room reservations

F E B RUA RY

*FHCA seminar:“Managing the Uncertainties

of Regulatory Compliance in aRisky Healthcare Environment”

Registration 7:30 - 8:30 a.m.; Program 8:30 a.m. - 4:00 p.m.

Wednesday 18...................Renaissance Orlando Resort At SeaWorld, 6677 Sea Harbor Drive, Orlando, 32821

Call (800) 468-3571 for reservations; main hotel number is (407) 351-5555.

Tuesday 17 .........................................Signature Grand6900 E. State Road 84, Davie, 33317 For directions,call the Signature Grand at (954) 424-4000. Roomreservations may be made at the Comfort Suites Ft.

Lauderdale Airport West, 2540 Davie Road Ext., Davie,33317 Call (954) 585-7071 for room reservations.

Thursday, February 26 FHCA committee meetings

Gaylord Palms Resort, Orlando

Friday, February 27 FHCA Board of Directors meeting

Gaylord Palms Resort, Orlando

M A R C HTuesday, March 16

FHCA Pre-Legislative MeetingEducational Seminar

Topic, times and schedule to be announcedHoliday Inn, 315 West Tennessee Street,

Tallahassee, 32301Call (850) 222-9555 or (800) 648-6135 for room

reservations. Ask for FHCA code HEA.Room reservations must be made by February 22, 2004.

Tuesday, March 16 FHCA Board of Directors

dinner meetingTallahassee

Wednesday 17 & Thursday 18FHCA & FALA 2004 Legislative MeetingDoubleTree Hotel Tallahassee,

101 South Adams Street, Tallahassee, 32301 Call (850) 224-5000 for room reservations.

Room rate $149 single/double, valid Tuesday, March 16th to Thursday, March 18th. Limited number of rooms on Tuesday.

Reservations must be made by February 24, 2004

A P R I L

Thursday, April 29 FHCA committee meetings

Boca Raton Resort & Club, Boca Raton

Friday, April 30 FHCA Board of Directors meeting

Boca Raton Resort & Club

M AY

May 6 National Nurses Day

May 9-16 National Nursing Home Week

May 26 – 28Nurse Leadership Training ProgramThe Don CeSar Beach Resort & Spa, 3400 Gulf Blvd.,St. Pete Beach, 33706. Make room reservations now

by calling (800) 282-1116. Room rate $99 single/dou-ble. Rate valid May 21 - 27, 2004. Reservations must

be made by April 21, 2004.

J U N E

June 28 & 29FHCA & FALA 2004 Trade Show

Booth layout and trade show contract available at www.fhca.org. Click on “Seminars/Events,”then “Annual Conference 2004.” Call Melody Gordon,

Director of Meeting Planning, or Kim Ross, MeetingPlanning Assistant, at (800) 771-3422.

June 28 – July 1FHCA & FALA 2004 Annual

Conference… Celebrating FHCA’s50th and FALA’s 10 AnniversariesBoca Raton Resort & Club, 501 East Camino Real,

Boca Raton, 33431. Call (888) 503-2622 for reservations. Main hotel number is (561) 447-3000. Rates: $99 Villa; $110 Cloister; $125 Tower & YachtClub; $140 Beach Club. Room block will open April1st for room reservations to be accepted at resort.

FHCA JANUARY 2004 Pulse 15

Letters from across Florida

Gracious and giving“I thank you so very much for the care you gaveto my mother.You are loving, gracious and giving.I will never forget the love you showed us both.”

—Susan O’Shea, to the staff of Wedgewood Healthcare Center, Lakeland

Model facility“During the four months (my mother) was in thefacility, my wife and I visited at various times dur-ing the day and night and got to know most ofthe facility personnel, including everyone from thecleaning staff, to the nursing staff, to the adminis-trative staff.All were caring people who were excel-lent in providing the next best care to what we hadtried to provide in our home.There was personalcare where each resident felt they were a very spe-cial person. I cannot say enough nice things aboutthe facility and the people who work there…TheState of Florida should use this facility as a modelfor others providing care to our loved ones.”

—Raymond S. Hart III, Wildwood, in a letterto the Withlacoochee Area LTC Ombudsman

Council about his positive experience withOsprey Pointe Nursing Center in Bushnell.

Pulse Page 16QMPW ad

pick-up from pg. 16 ofDecember 2003 Pulse.

2-color