F-tag 314: Prevention and Management of Pressure Ulcers

David R. Thomas, M.D.

Two Congressional acts, the Omnibus Budget Reconciliation Act of 1987 (OBRA '87) and the Balanced Budget Act of 1997 (BBA '97), contained regulations governing practices in the nursing home. OBRA '87 had a major impact on general nursing care, including the Minimum Data Set (MDS), requirements for a medical director, and reduction of physical and chemical restraints. Regulations based on BBA '97 initiated the Prospective Payment System and consolidated billing. These federal regulations have in effect created a standard of care in nursing facilities.

The regulations resulting from OBRA '87 are divided into 2 parts. First, the regulation is stated. These statements are labeled by F-tags and a number. An F-tag is jargon for the actual regulation published in the Federal Register. The second part consists of an Interpretive Guideline. The Interpretive Guideline is derived by the agency responsible for enforcing the regulation. It consists of an explanation of the intent of the law, definitions of terms, and instructions on determining compliance with the law. The guideline is supplemented by an Investigative Protocol that is used to document compliance.

The Center for Medicare Services continually produces revisions of the Interpretive Guidelines for Surveyors for use in nursing homes. New guidelines for the prevention and treatment of pressure ulcers were introduced in November 2004.1 State and federal surveys in nursing homes performed since then have used the new interpretive guidelines. The guidelines were produced by a consensus committee and thus will engender some disagreement over individual items. However, the new guidelines are much more evidence-based and an improvement over the previous versions.

The original law published in the Federal Register is simple and unchanged: “Based on the comprehensive assessment of a resident, the facility must ensure that (1) A resident who enters the facility without pressure sores does not develop pressure sores unless the individual’s clinical condition demonstrates that they were unavoidable; and, (2) A resident having pressure sores receives necessary treatment and services to promote healing, prevent infection, and prevent new sores from developing.” The extensive revisions to the new Interpretive Guideline derive from this regulation. This review will focus on the changes to the guidelines for the prevention and management of pressure ulcers.

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The New F-tag 314 –
Overview of the new F-tag 314 regarding the prevention and treatment of pressure ulcers