February 22, 2012_NH "Dear Administrator" Letters

February 22, 2012

ADSA: NH #2012-002
Dear Nursing Facility/Home Administrator:

The purpose of this letter is to let you know that the Department is releasing its updated Nursing Home Guidelines – Fifth Edition, also commonly known as the "Purple Book".  The primary reason for this update (February 2012) is to incorporate the Centers for Medicare and Medicaid Services (CMS) earlier survey and certification memorandum on required facility responsibilities for reporting reasonable suspicion of a crime against a resident in a long-term care facility. 

In August 2011, the Department issued Dear NH Administrator - ADSA:  NH #2011-013, a letter about these CMS facility reporting requirements.  A link to the S&C Memo is included below for your reference and review. The 2010 federal health care legislation adopted new requirements for the reporting of possible crimes in long-term care facilities, including nursing facilities and skilled nursing facilities.  Covered individuals, including facility employees, must report any reasonable suspicion of a crime against a resident of a long-term care facility, or against an individual receiving care from the facility.  Some requirements of the law were new and some of them already existed under state law. 

If there is a difference between federal and state reporting requirements, you must follow whichever law is the most stringent. If you would like to review again nursing facilities and skilled nursing facilities' responsibilities and other details of the memorandum online, please visit:  https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/index.html?redirect=/SurveyCertificationGenInfo/PMSR/itemdetail.asp

Since it is essential to be clear about the differences between federal and Washington State reporting requirements, the Department did a full review of the prior "Purple Book".  This allowed the Department to make changes to reflect this federal health care legislation.  This also gave the Department an opportunity to update other content as well as enhance the format of this Fifth Edition.   When compared to the Fourth Edition, there are some new resources included, and some core information has been reorganized and/or relocated to different sections of the document. 

Here are two examples, but not all, of the changes made to these NH Guidelines:  

  • There are new Appendices on several topics – Key Triggers / Possible Criminal Indicators of types of Abuse, Neglect, Financial Exploitation; Medicaid Fraud Control Unit; Selected Resources; and, the Complaint Resolution Unit (CRU) Hotline Poster; and
  • The "Definitions" section has been expanded and this content is now found in an Appendix, rather than in a Chapter. 

The Department is only able to provide this document, Nursing Home Guidelines – Fifth Edition, in an online version,as printing and mailing hard copies NH facilities statewide is too cost prohibitive, given current state agency staffing resources and
budgetary constraints.

Upon receipt of this letter, you and your staff members can access the document online to print it, and, then check periodically for updates to this Nursing Home Guidelines ("Purple Book") by visiting:  http://www.adsa.dshs.wa.gov/professional/nh.htm.

You and your staff are encouraged to become thoroughly familiar with the content and layout of this Fifth Edition of these updated Nursing Home Guidelines. This Fifth Edition does not necessitate formal training by the Department for nursing facilities, skilled nursing facilities, and, ICFs/ID facilities and their respective staff members who are mandated reporters.  For quality assurance purposes, these Guidelines are effective immediately.

Each resident in nursing facilities or skilled nursing facilities deserves our full efforts to keep him or her from being harmed by, or being placed at risk for, abuse of all types, neglect, criminal mistreatment, abandonment, and, financial exploitation.  Thank you for your ongoing work with Residents as "Partners in Protection" with the Department.

Please contact your local RCS Field Manager if you have any questions.


Joyce Pashley Stockwell, Director
Residential Care Services