AEM Training Guide
ASPEN Enforcement Manager
(AEM)
For Nursing Home Enforcement Cases
Training Guide
February 2003
30
AEM Training Guide
Contents
Introduction 3
Exercise I. Getting Acquainted—an AEM Overview 4
Task 1: Moving around in AEM 4
The Enforcement Explorer View 4
My Cases 5
Special Cases 6
My Action Items 7
Using Find to locate facilities and cases 8
Task 2: Examining an AEM case file 9
Opening a new case 9
Reviewing the tabs 10
Title Bar and Case Header 11
Case Basics tab 12
Surveys & IDR tab 13
Remedies tab 14
CMP tab 15
NATCEP tab 16
Notices tab 17
Hearing/Appeal tab 18
Task 3: Managing case files 19
Basic concepts 19
What is Cycle Start? ¾ Health and LSC Enforcement tracks ¾ Combined Health/LSC Enforcement tracks
Case management procedures 20
How to add a survey to a case ¾ Changing case status/Closing a case ¾
Hover Guidance
Exercise II. Configuring AEM for your State or CMS Region 23
Task 1: Adding State Enforcement remedies 24
Task 2: Entering distribution recipients 26
Task 3: Customizing Enforcement letters 27
Viewing the CMSO Letter Templates 27
Creating a custom letter from a CMSO template 28
Exercise III. Case Scenarios 31
Scenario A 33
Scenario B 39
Scenario C 59
30
AEM Training Guide
Introduction
What is an ASPEN Enforcement case?
An Enforcement case is a process of monitoring Nursing Home (NH) facilities to ensure that they remedy deficient practices and establish procedures that will sustain continued compliance. In severe instances of non-compliance, NH Enforcement allows imposition of significant sanctions against the nursing home, including monetary penalties and program termination.
An Enforcement case is initiated, typically by the State Agency (SA), when the survey of a Nursing Home results in findings of deficiencies with scope and severity of D or above. Once an enforcement case begins, additional survey visits may be added to the cycle.
ASPEN Enforcement Manager (AEM) enables both State Agency and CMS Regional Office (RO) staff to efficiently manage all tasks related to NH Enforcement. Case workers can assign cases and perform activities such as case definition, assignment and maintenance; management of immediate jeopardy (IJ) situations; remedy determination; assessment of Civil Money Penalties (CMPs); NATCEP-related tasks, and Hearing and Appeals tracking.
An Enforcement cycle ends with either compliance or termination (voluntary or involuntary). A single cycle cannot exceed 6 months. In AEM, a case may remain open until all appeals are exhausted and all CMPs paid.
How is Enforcement management integrated into ASPEN?
ASPEN Enforcement Manager is configured as an additional view—on the Enforcement tab—in ASPEN Central/Regional Office (ACO/ARO). AEM shares all facility, certification, complaint, and citation information already captured within ACO/ARO and the ASPEN Complaints Tracking System (ACTS). While you can view survey information in AEM, most survey and certification data will continue to be entered and maintained directly in ACO/ARO.
When working in an Enforcement case, you have a read-only view of facilities and surveys that are linked to the case, and can make changes to dates (POC tracking dates, for instance) that are relevant to Enforcement. Changes made in AEM will be visible elsewhere in ACO the next time the survey is opened.
Exercise I. Getting Acquainted—an AEM Overview
You won't need your computers for this first exercise. The instructor will go through these introductory tasks on the training screen.
Task 1: Moving around in AEM
The AEM Tree provides a number of ways you can view and open enforcement cases. Learning to use the features of the tree can save considerable time when working in the application.
· The Enforcement Explorer View
When you click the Enforcement tab, the initial display contains the AEM Tree in the left pane, and a list of your Action Items on the right. This main view is called the Enforcement Explorer view.
Figure 1
· My Cases
My Cases gives you a quick list of just those cases to which you have been assigned as case worker.
When you highlight the My Cases node, the List View provides a line summary of each case.
Figure 2
· Special Cases
The Special Cases node in the AEM tree organizes enforcement cases four different ways to assist you in quickly locating important cases. These options are:
× Active IJ Cases—Cases with an Immediate Jeopardy (IJ) situation that have a Current status
× All IJ Cases—Cases with IJ situations that have either Current or Removed status
× Open Cases—All open cases
× No Opportunity to Correct Cases—Cases with a Beginning Case Type of No Opportunity to Correct
Follow the steps on Figure 3 to see how you can quickly access details about an enforcement case by manipulating the tree.
1 Under Special Cases, click the + next to All IJ Cases to expand the node.
2 Expand one of the cases to see all the surveys belonging to it listed beneath it in the tree.
3 Highlight one of the surveys to see its citations listed in the List view on the upper right.
4 in the List view, highlight a citation to read its findings in Detail view.
Figure 3
· My Action Items
The Action Items list notifies staff members of tasks that require attention, or can even remind you of important next steps in your cases’ enforcement cycles.
Tasks and Action Items are created within an Enforcement case and can be assigned to any current staff member. Additionally, Action Item notices are automatically created by ASPEN. When a survey is created (either through ASPEN Central/Regional Office (ACO/ARO) or the ASPEN Complaint Tracking System (ACTS)) for an NH facility with an active enforcement case in AEM, that visit is automatically added to the enforcement case and a SURVEY/REVISIT ADDED Action Item is automatically sent to all case workers assigned to the enforcement case.
Highlight My Action Items to see them listed on the right List View.
Figure 4
· Using Find to locate facilities and cases
As in other areas of ACO, there is a Find button at the top of the Enforcement tab tree view that you can use to locate a facility or a case. The Enforcement Find window has additional criteria to facilitate finding Enforcement case records.
1 Click Find to open the Find window.
Figure 5
2 In the Text box, type in a search string — the characters, alpha or numeric, that you want ASPEN to find.
3 Click a search Type to select it. In Figure 5, we’re using Facility Name.
4 Click Find Now. Records matching the search string will show in the Search Results box.
5 Highlight the record you want, and click Go To Case. AEM will locate the facility in the tree.
6 In the tree, click the + to the left of the facility name to show the Enforcement cases.
7 Right-click the case you want and select Modify Enforcement.
Task 2: Examining an AEM case file
We'll open a case, and have a quick overview of the screens contained in an enforcement record.
· Opening a new case
1 In ACO (or ARO), go to the Enforcement tab, then locate the facility of interest in the tree. Right-click the name, and select New Enforcement. /Figure 6
The Begin Enforcement Cycle window will appear with a list of surveys.
2 Select the survey that initiated the case and click OK to create a new case record.
Figure 7
· Reviewing the tabs
An Enforcement record in AEM contains seven tabs, plus the case header that remains visible at all times:
× Case Header
× Case Basics
× Surveys & IDR
× Remedies
× CMP
× NATCEP
× Notices
× Hearing/Appeal
We’ll review the uses and contents of each. If you’re curious about a particular field on any tab, go to that tab's section in the Field Definitions chapter.
Title Bar and Case Header
The Title bar (the horizontal bar at the top of the window) shows the Case ID, the facility name, the Cycle Start Date and the current status of the case.
The Case Header remains visible no matter where you are in the case file, offering a quick reference to the Latest Alleged Compliance Date (the date by which the facility states it will be in substantial compliance), along with calculations of key case milestones for 23 days, 3 months and 6 months from the Cycle Start date.
The Facility Detail button on the right opens a read-only view of Facility Properties.
Figure 8
Case Basics tab
The first tab in the Enforcement record, Case Basics, will be the active tab whenever you open a case. It contains important case status information and dates, as well as the names of case workers assigned to the case with their contact information, a list of the Action Items/Next Steps related to the case, and a Notepad where you can enter notes and messages about the case.
Figure 9
Surveys & IDR tab
The top of the Surveys and IDR tab is the Cycle Surveys and Citations Management section, with three subtabs:
Surveys ¾ one-line summaries of surveys associated with the case/cycle.
IJ Situation ¾ tracks IJ dates and associated survey information.
Citations: All Surveys ¾ provides a master list of all of the deficiencies cited on all of the surveys related to the case, with current completion and correction dates.
When the Surveys subtab is active, you can select any survey, and AEM will provide a detailed display of IDR information about that survey in the section below.
Figure 10
Remedies tab
The Remedies tab is where you will enter Federal and/or State remedies as they are recommended, and track the progress of existing remedies.
Figure 11
CMP tab
The CMP tab stores information about the CMP process, from recommendation to imposition. Additionally, you can maintain payment status and history for multiple CMPs on this tab.
The top of the tab summarizes information about all the CMPs related to the case; the middle section lists individual CMPs. When you select a CMP from this list, its details, including payment history, are itemized in the bottom section of the tab.
Figure 12
NATCEP tab
The NATCEP tab lists NATCEP triggers and waiver information, and provides a place to enter applicable dates.NATCEP dates entered here are also viewable in Facility Properties, on the Other tab.
Figure 13
Notices tab
The Notices tab stores a history of all letters and notices sent regarding this case/cycle. You generate letters, notices, action items and other communications from this tab.
When you select a letter in the Notices grid, the Details section provides a quick view of the type of notices it contained and the date sent and/or delivered. Not all correspondence with the provider is listed here, only correspondence related to the current case.
Figure 14
Hearing/Appeal tab
The Hearing/Appeal tab provides places for entry of all appeal-related information, including relevant request dates, docket numbers, and decision information.
Figure 15
Task 3: Managing case files
· Basic concepts
There are some basic concepts to keep in mind when working with AEM enforcement cases.
What is Cycle Start?
The survey which is used to create an enforcement case is referred to as the "starting survey". Usually, the exit date of this starting survey represents the start date of the enforcement cycle. There is an exception when the case involves an IJ situation that occurred before the starting survey; for such a case the date of the IJ begins the cycle. The Cycle Start date begins the six-month clock during which the facility must come into compliance or face termination. Other important enforcement milestone dates are based on the Cycle Start date.
Note: After discussions in the AEM Training classes and Workgroup meetings, Cycle Start is being redefined for v7.0 (July 2003). With v7.0, the IJ qualifier will be removed, and Cycle Start will always be clocked from the exit date of the starting survey.
Health and LSC Enforcement tracks
You can create an Enforcement case for any NH facility type – certified, licensed or both. Enforcement cycles may be initiated by either a Health or a Life Safety Code (LSC) survey type. You can simultaneously have an active Health and an active LSC case open, but you cannot have more than one case of the same type active at the same time.
If you have an open enforcement case that was initiated by a Health survey, you cannot open a new enforcement case based on a subsequent Health visit. In this instance, the later Health survey should be added to the existing active Health enforcement case.
Once an enforcement case is defined by either a Health or an LSC survey, only visits of that type can be added to the case, except in the case of Combined Health/LSC Enforcement Tracks.
Combined Health/LSC Enforcement tracks
AEM will allow a combined Health and LSC enforcement case if the case is initiated by Health and LSC visits that are performed within 7 days of each other. The 7-day window is defined as extending from the exit date of the earlier survey to the start date of the later survey. If you have a combined Health/LSC case, you can add subsequent visits of either type to the case.