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United States Government Accountability Office: 
GAO: 

Report to the Ranking Member, Committee on Veterans' Affairs, U.S. 
Senate: 

October 2011: 

VA Community Living Centers: 

Actions Needed to Better Manage Risks to Veterans' Quality of Life and 
Care: 

GAO-12-11: 

GAO Highlights: 

Highlights of GAO-12-11, a report to the Ranking Member, Committee on 
Veterans’ Affairs, U.S. Senate. 

Why GAO Did This Study: 

The Department of Veterans Affairs (VA) annually provides care to more 
than 46,000 elderly and disabled veterans in 132 VA-operated nursing 
homes, called community living centers (CLC). After media reports of 
problems with the care delivered to veterans in CLCs, VA contracted 
with the Long Term Care Institute, Inc. (LTCI), a nonprofit 
organization that surveys nursing homes, to conduct in-depth reviews 
of CLCs in 2007-2008 and again in 2010-2011. GAO was asked to evaluate 
VA’s approach to managing veterans’ quality of care and quality of 
life in CLCs. This report examines (1) VA’s response to and resolution 
of LTCI-identified deficiencies and (2) information VA collects about 
the quality of care and quality of life in CLCs and how VA uses it to 
identify and manage risks. To do this work, GAO interviewed officials 
from VA headquarters, examined all 116 2007-2008 and 67 2010-2011 LTCI 
reviews, and analyzed 50 CLCs’ corrective action plans for 2007-2008 
and 23 such plans for 2010-2011. 

What GAO Found: 

VA headquarters established a process for responding to deficiencies 
identified at CLCs during the 2007 and 2008 LTCI reviews. VA is using 
the process, which requires CLCs to submit corrective action plans 
addressing LTCI-identified deficiencies—-such as how CLCs will address 
a lack of competent nursing staff and a failure to provide a sanitary 
and safe living environment—-during the 2010 and 2011 LTCI reviews. On 
the basis of its analysis of the deficiencies identified in 2007 and 
2008, VA headquarters also developed a national training and education 
initiative. VA headquarters officials told GAO that they plan to 
analyze the deficiencies identified during the 2010 and 2011 reviews 
and identify national areas for improvement. However, GAO found 
weaknesses in VA’s process for responding to and resolving LTCI-
identified deficiencies. First, VA headquarters does not maintain 
clear and complete documentation of the feedback it provides to CLCs 
regarding their corrective action plans. Second, VA headquarters does 
not require VA’s networks, which oversee the operations of VA medical 
facilities, including CLCs, to report on the status of CLCs’ 
implementation of corrective action plans or to verify CLCs’ self-
reported compliance with the requirements of the national training and 
education initiative. Because of these weaknesses, VA headquarters 
cannot provide reasonable assurance that LTCI-identified deficiencies 
are resolved. For example, without requiring networks to report on the 
status of CLCs’ implementation of their corrective action plans, VA 
headquarters cannot determine whether CLCs’ corrective action plans 
are fully implemented. Unaddressed, weaknesses in VA headquarters’ 
process for responding to LTCI-identified deficiencies may compromise 
the quality of care and quality of life of veterans in CLCs. 

VA headquarters’ current approach to identifying risks associated with 
the quality of care and quality of life of CLC residents does not 
comprehensively analyze information from all available sources, and 
for the sources VA does analyze, it does not compare findings across 
sources. VA’s approach relies significantly on the analysis of 
findings from LTCI reviews of CLCs. However, in addition to LTCI 
reviews, VA headquarters obtains information about CLCs from a variety 
of other sources, such as VA’s Office of Inspector General (OIG), but 
does not analyze the information from all these other sources. 
Further, for the sources it does analyze, VA headquarters evaluates 
each source in isolation and does not compare the findings from one 
source with findings from the other sources. Therefore, VA headquarters’
 current approach to identifying risks in CLCs may result in missed 
opportunities to detect patterns and trends in information about the 
quality of care and quality of life within a CLC or across many CLCs. 
For example, in comparing findings from VA’s Office of the Medical 
Inspector, OIG, LTCI, and VA’s quality indicator and quality measure 
data for one CLC, GAO found a pattern of deficiencies related to pain 
management. Without considering information from all available sources 
and comparing it across sources, VA headquarters cannot fully identify 
risks in CLCs, estimate the significance of the risks, or take actions 
to mitigate them. 

What GAO Recommends: 

GAO recommends that VA document feedback to CLCs and require periodic 
status reports about corrective action plan implementation, and 
implement a process to comprehensively identify and manage risks to 
residents in CLCs by analyzing and comparing information about 
residents’ quality of care and quality of life. In its comments on a 
draft of this report, VA concurred with these recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-12-11]. For more 
information, contact Randall Williamson at (202) 512-7114 or 
williamsonr@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

VA Headquarters Established a Process for Responding to LTCI-
Identified Deficiencies, but Cannot Provide Reasonable Assurance That 
Deficiencies Have Been Resolved: 

VA Headquarters Receives Information about CLCs from Multiple Sources, 
but Does Not Analyze It to Assess and Manage Risks: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: VA Headquarters' Analysis of Information about the Quality 
of Life and Care in Community Living Centers: 

Appendix II: Comments from the Department of Veterans Affairs: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Table: 

Table 1: Clinical High-Risk Categories Defined by VA Headquarters' 
Analysis of Deficiencies Identified in 2007 and 2008 Long Term Care 
Institute, Inc., Reviews: 

Abbreviations: 

CLC: community living center: 

LTCI: Long Term Care Institute, Inc. 

OIG: Office of Inspector General: 

OMI: Office of the Medical Inspector: 

PICC: peripherally inserted central catheter: 

SOARS: System-wide Ongoing Assessment and Review Strategy: 

VA: Department of Veterans Affairs: 

VAMC: VA medical center: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

October 19, 2011: 

The Honorable Richard Burr: 
Ranking Member: 
Committee on Veterans' Affairs: 
United States Senate: 

Dear Senator Burr: 

The Department of Veterans Affairs (VA) spent more than $4.5 billion 
on nursing home care in fiscal year 2010, over $3.3 billion of which 
was for care in 132 VA-operated nursing homes, called community living 
centers (CLC).[Footnote 1] CLCs offer a range of services that include 
short-term postacute rehabilitation for conditions such as a stroke; 
long-term care for veterans who cannot be cared for at home because of 
severe and chronic physical or mental limitations; and end-of-life 
care for terminal illnesses. More than 46,000 elderly and disabled 
veterans annually receive care in CLCs. This vulnerable population 
relies on VA to ensure they receive quality care and maintain their 
quality of life while residing in a CLC.[Footnote 2] 

In 2004, problems related to the care and conditions in one CLC 
surfaced in the media, raising concerns about the effectiveness of 
VA's efforts to manage the quality of care and quality of life in its 
CLCs. In response, VA headquarters had in-depth unannounced reviews 
conducted at selected CLCs between August 2004 and November 2006, and 
contracted with the Long Term Care Institute, Inc. (LTCI), in March 
2007 to conduct in-depth reviews of 116 CLCs.[Footnote 3] LTCI 
conducted its reviews between June 2007 and September 2008.[Footnote 
4] In late 2009, a series of newspaper articles reported the details 
of deficiencies that LTCI had identified at another CLC in September 
2008. Specifically, the articles reported a lack of competent skilled 
nursing in the CLC as well as failure to provide a sanitary and safe 
living environment, promote and protect veterans' rights to autonomy, 
and treat veterans with respect and dignity. 

Recognizing the value of the information obtained from the in-depth 
reviews of CLCs, VA headquarters awarded a second contract in July 
2010 to LTCI to begin reviewing all 132 CLCs in September 2010. In 
light of this contract and the 2009 newspaper articles, you raised 
questions about VA's process for responding to the deficiencies 
identified during the LTCI reviews, as well as the agency's overall 
approach to managing the quality of care and quality of life in its 
CLCs. These questions included how VA headquarters uses available 
information regarding the quality of care and quality of life in its 
CLCs, such as the deficiencies cited by LTCI, to identify patterns and 
associated risks and take appropriate actions to address those risks. 
This report examines (1) actions VA headquarters has taken to respond 
to and resolve LTCI-identified deficiencies and (2) what information 
VA headquarters collects regarding the quality of care and quality of 
life in CLCs and the extent to which VA headquarters uses the 
information to identify and manage risks. 

To examine actions VA headquarters has taken to respond to and resolve 
deficiencies LTCI identified during its 2007 and 2008, and 2010 and 
2011, reviews of CLCs, we obtained and analyzed copies of the 116 LTCI 
reviews performed during 2007 and 2008; VA headquarters' subsequent 
analyses of those reviews; copies of 50 CLCs' corrective action plans 
and related documentation from the 2007 and 2008 reviews;[Footnote 5] 
copies of the 67 LTCI reviews performed between September 1, 2010, and 
March 31, 2011; and copies of 23 CLCs' corrective action plans from 
the 2010 and 2011 reviews.[Footnote 6] We also reviewed relevant VA 
policy documents, including Veterans Health Administration Directive 
2009-43, Quality Management System. We interviewed officials from VA 
headquarters offices involved in responding to LTCI-identified 
deficiencies, including the Office of Geriatrics and Extended Care and 
the Office of the Deputy Under Secretary for Health for Operations and 
Management.[Footnote 7] In addition, we reviewed Executive Career 
Field Plans of VA network directors and interviewed officials from 2 
of VA's 21 networks, which oversee the operations of the various 
medical facilities within their assigned geographic area. These two 
networks were the VA Mid-Atlantic Health Care Network (Durham, North 
Carolina) and the VA Northwest Health Network (Vancouver, Washington). 
To select the networks, we considered the average number of 
deficiencies per CLC reviewed by LTCI in 2007 and 2008.[Footnote 8] We 
assessed VA headquarters' response to the identified deficiencies in 
the context of federal standards for internal control for monitoring, 
control activities, and information and communications.[Footnote 9] 
The internal control for monitoring refers to an agency's ability to 
provide reasonable assurance that actions are taken in response to the 
findings from reviews and the deficiencies identified are promptly 
resolved, while the internal control for control activities refers to 
an agency's ability to provide reasonable assurance that management's 
directives are carried out, which includes appropriately documenting 
transactions and internal controls. The internal control for 
information and communications refers to an agency's ability to 
provide reasonable assurance of the relevance and reliability of 
information necessary to achieve an agency's objectives, including 
verifying the accuracy of its data. 

To determine what information VA headquarters collects regarding the 
quality of care and quality of life in CLCs and the extent to which VA 
headquarters uses the information to identify and manage risks, we 
reviewed reports from reviews and investigations performed at CLCs 
between June 2007 and June 2011. We also reviewed VA analyses of 
information contained in these reports and VA policy documents. We 
interviewed officials from Geriatrics and Extended Care; the Office of 
the Deputy Under Secretary for Health for Operations and Management; 
the Office of the Assistant Deputy Under Secretary for Health for 
Informatics and Analytics; the Office of the Assistant Deputy Under 
Secretary for Health for Quality, Safety, and Value; and the Office of 
Inspector General (OIG). We assessed VA headquarters' use of 
information regarding the quality of care and quality of life in CLCs 
in the context of federal standards for internal control for risk 
assessment. The internal control for risk assessment refers to an 
agency's ability to identify and analyze relevant risks associated 
with achieving its objectives. 

We conducted this performance audit from August 2010 through September 
2011 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

VA provides nursing home care for some veterans, as required, and 
makes these services available to other veterans on a discretionary 
basis, as resources permit.[Footnote 10] Specifically, VA is required 
by law to provide nursing home care to any veteran who needs it for a 
service-connected disability and to any veteran who needs it and has a 
service-connected disability rated at 70 percent or greater.[Footnote 
11] However, VA provides most of its nursing home care to veterans on 
a discretionary basis, as resources permit.[Footnote 12] VA's policy 
on nursing home eligibility requires that VA networks provide nursing 
home care to veterans with 60 percent service-connected disability 
ratings who are either unemployable or who have been determined by VA 
to be permanently and totally disabled. For all other veterans, VA's 
policy is to provide nursing home care on a discretionary basis, with 
certain veterans having higher priority, including veterans who 
require care following a hospitalization. 

CLCs provide both short-stay (90 days or less) and long-stay (more 
than 90 days) services. According to VA data, almost 94 percent of the 
residents admitted to CLCs in fiscal year 2010 were short-stay. Short- 
stay care in CLCs includes skilled nursing care, rehabilitation, 
restorative care, maintenance care for those awaiting alternative 
placement, hospice, and respite care. The remaining admissions, about 
6 percent, were long-stay. Long-stay care includes dementia care, 
maintenance care, and care for those with spinal cord injury and 
disorders. 

Responsibility for VA's medical facilities, including CLCs, rests with 
both VA's networks and VA headquarters. Almost all of VA's 132 CLCs, 
located throughout VA's 21 networks, are colocated with or in close 
proximity to a VA medical center (VAMC). While networks are charged 
with the day-to-day management of the VAMCs within their network, VA 
headquarters maintains responsibility for establishing national policy 
and overseeing both networks and VAMC operations. Within VA 
headquarters, Geriatrics and Extended Care is responsible for 
developing VA's policies and other national actions related to the 
quality of care and quality of life in VA's CLCs. The Office of the 
Deputy Under Secretary for Health for Operations and Management, 
through each network, ensures that VAMCs, including CLCs, comply with 
VA's policies and implement other national actions. 

The LTCI contract, which began in September 2010, is for 1 year, and 
provides for LTCI to conduct reviews between September 2010 and August 
2011. VA may exercise an option to renew for each of 4 additional 
years through August 2015.[Footnote 13] Officials from both Geriatrics 
and Extended Care and the Office of the Deputy Under Secretary for 
Health for Operations and Management share responsibility for 
administering VA's contract with LTCI. 

LTCI uses the Centers for Medicare & Medicaid Services' scope and 
severity scale for classifying nursing home deficiencies. There are 
four severity classifications, with the least serious deficiencies 
rated as having the potential for minimal harm and the most serious 
deficiencies rated as immediate jeopardy situations--in which 
residents are potentially or actually at risk of dying or being 
seriously injured. The remaining two severity classifications are 
actual harm and potential for more than minimal harm. The scope of 
deficiencies--or the number of residents potentially or actually 
affected by the deficient care--may be rated as isolated, pattern, or 
widespread. 

VA policy requires that all VAMCs be accredited by The Joint 
Commission.[Footnote 14] As part of the accreditation process for a 
VAMC, which occurs on average every 3 years, The Joint Commission 
surveys and accredits any CLC associated with the VAMC.[Footnote 15] 
VA requires CLCs to meet The Joint Commission long-term care 
standards.[Footnote 16] CLCs are also subject to periodic reviews by 
VA's OIG. 

VA Headquarters Established a Process for Responding to LTCI-
Identified Deficiencies, but Cannot Provide Reasonable Assurance That 
Deficiencies Have Been Resolved: 

VA headquarters established a process for responding to deficiencies 
identified at CLCs during the 2007 and 2008 reviews. This process, 
which requires CLCs to submit corrective action plans addressing LTCI- 
identified deficiencies--such as how CLCs will address a lack of 
competent nursing staff and a failure to provide a sanitary and safe 
living environment--is also being used during the 2010 and 2011 LTCI 
reviews. However, because of weaknesses in the process, VA 
headquarters cannot provide reasonable assurance that deficiencies 
that could potentially affect the quality of care and quality of life 
of residents are resolved. 

VA Headquarters' Process Requires Corrective Action Plans and, for 
2007 and 2008, National Training and Education: 

VA headquarters established a process for responding to LTCI-
identified deficiencies that requires each CLC to develop a corrective 
action plan addressing all deficiencies identified and submit it to VA 
headquarters within 30 days of receiving an LTCI report. The plans may 
include actions such as training CLC staff on clinical policies and 
procedures or implementing nursing and interdisciplinary rounds to 
monitor the clinical issues related to the deficiencies. VA 
headquarters officials review each corrective action plan to determine 
whether the actions can be expected to correct all identified 
deficiencies and whether the time frames for completing the actions 
are reasonable. The officials then provide each CLC feedback by 
telephone, discussing any revisions to the corrective action plans 
that may be necessary. The officials document these discussions using 
hand-written notes on hard copies of CLCs' corrective action plans, 
which are not shared with VA networks and CLCs. VA headquarters 
officials told us they may schedule additional telephone calls with 
CLCs when significant revision of a corrective action plan is 
necessary or if the officials want an update on the implementation of 
the plan. For deficiencies identified in the 2007 and 2008 LTCI 
reviews, the documentation showed that officials had at least two 
telephone calls with 29 of the 116 CLCs reviewed.[Footnote 17] Three 
of these 29 CLCs received more than two follow-up calls. When 
additional calls were made, VA headquarters required the CLCs to 
submit an updated corrective action plan. 

While VA's process requires that all deficiencies identified be 
addressed, it gives priority to deficiencies at the immediate jeopardy 
or actual harm levels. When LTCI review teams identify such 
deficiencies during a survey, they are required to notify VA 
headquarters and the relevant VAMC.[Footnote 18] LTCI identified 
immediate jeopardy or actual harm deficiencies at 25 of the 116 CLCs 
(about 22 percent) reviewed in 2007 and 2008, and at 10 of the 67 CLCs 
(about 15 percent of the CLCs) reviewed in 2010 and 2011 as of March 
31, 2011.[Footnote 19] 

After the 2007 and 2008 LTCI reviews, VA headquarters officials 
analyzed the deficiencies from the 116 reviews and from the analysis 
developed eight clinical high-risk categories. According to these 
officials, the eight categories, which included medication management, 
infection control, and peripherally inserted central catheter (PICC) 
lines, posed the greatest risk to residents' health and 
safety.[Footnote 20] (See table 1.) The officials then implemented a 
national training and education initiative to address the eight 
categories. 

Table 1: Clinical High-Risk Categories Defined by VA Headquarters' 
Analysis of Deficiencies Identified in 2007 and 2008 Long Term Care 
Institute, Inc., Reviews: 

Category: Dignity; 
Percentage of 116 CLCs with related deficiencies[A]: 90; 
[Empty]; 
Examples of deficiencies: 
* Residents lacked privacy, including exposure during care; 
provision of care in public areas, such as applying ointment to a 
resident's upper body in the dining room in front of other residents; 
and uncovered catheter bags attached to residents' wheelchairs; 
* Residents had poor hygiene, including having dirty fingernails, not 
being shaven or bathed, and generally looking unkempt. 

Category: Medication management; 
Percentage of 116 CLCs with related deficiencies[A]: 78; 
[Empty]; 
Examples of deficiencies: 
* Residents were not assessed prior to administering medication (e.g., 
blood pressure not taken before administering hypertension medication 
or blood sugar testing not completed before administering insulin); 
* Medication was not administered according to policy and procedures. 
For example, staff did not document insulin injection sites or check 
documentation for prior insulin injection sites to ensure that insulin 
would not be injected routinely into the same site. Not rotating 
insulin injection sites can lead to hardening of the skin or weakening 
of fatty tissue under the skin. These can change the way insulin is 
absorbed, making it difficult to manage blood glucose levels. 

Category: Infection control; 
Percentage of 116 CLCs with related deficiencies[A]: 59; 
Examples of deficiencies: 
* Staff did not adhere to proper isolation procedures (e.g., entering 
and exiting rooms of residents with infectious diseases without 
wearing or removing protective gowns and gloves); 
* Staff did not follow handwashing policies and procedures. 

Category: Psychotropic medications[B]; 
Percentage of 116 CLCs with related deficiencies[A]: 47; 
Examples of deficiencies: 
* Staff administered psychotropic medications as a restraint and 
beyond the scope of the physician's original order (e.g., using 
psychotropic medications to calm residents before trying other 
nonpharmacological interventions to manage behavior); 
* Staff did not track and review residents' behavior to help ensure 
that use of a psychotropic medication was appropriate. 

Category: Percutaneous endoscopic gastrostomy tubes[C]; 
Percentage of 116 CLCs with related deficiencies[A]: 30; 
Examples of deficiencies: 
* Staff did not ensure full doses of medications were administered; 
* Residents experiencing significant weight loss were not assessed by 
a practitioner. 

Category: Restraints; 
Percentage of 116 CLCs with related deficiencies[A]: 28; 
Examples of deficiencies: 
* Staff were not trained to know which devices were classified as 
restraints and therefore used restraints without physician 
authorization (e.g., staff used bed rails, seat belts, and tables to 
restrict resident mobility, all of which are classified as restraints). 

Category: Pressure ulcers[D]; 
Percentage of 116 CLCs with related deficiencies[A]: 24; 
Examples of deficiencies: 
* Residents were not regularly assessed for having or being at risk 
for pressure ulcers; 
* Residents with pressure ulcers did not receive proper care, 
including wound care. 

Category: Peripherally inserted central catheter (PICC) lines[E]; 
Percentage of 116 CLCs with related deficiencies[A]: 21; 
Examples of deficiencies: 
* Staff did not properly prepare lines (e.g., did not flush lines) 
before and after administering medications, when required; 
* Staff did not follow procedures for dressing changes of PICC lines, 
which could increase the risk of local or systemic infection. 

Source: Long Term Care Institute, Inc. (LTCI), and VA data. 

Notes: GAO analyzed data contained in the 2007 and 2008 LTCI reviews 
and data provided by VA headquarters based on its analysis of the 2007 
and 2008 LTCI reviews. 

[A] Represents the percentage of 116 community living centers (CLC) 
where LTCI identified at least one deficiency related to that category 
in 2007 or 2008. 

[B] A psychotropic medication is any medication whose intended purpose 
is to alter perception, mental status, or behavior. Examples of drug 
classes include antipsychotic, antidepressant, and antianxiety 
medications. 

[C] A percutaneous endoscopic gastrostomy tube is a flexible feeding 
tube that is placed through the abdominal wall and into the stomach to 
allow nutrition, fluids, and medications to be put directly into the 
stomach. 

[D] Pressure ulcers are areas of damaged skin caused by staying in one 
position for too long. They commonly form where bones are close to the 
skin, such as ankles, back, elbows, heels, and hips. Residents are at 
risk if they are bedridden, use a wheelchair, or are unable to change 
position. Pressure ulcers can lead to serious infections, some of 
which are life-threatening. 

[E] A central line is a small tube that is placed in a large vein in 
the neck, chest, groin, or arm to give fluids, blood, or medications 
or to do medical tests quickly. A central line can remain for weeks or 
months, and some patients receive treatment through the line several 
times a day. A PICC line is a specific type of central line that is 
placed into a vein in the arm. 

[End of table] 

VA headquarters convened a workgroup that developed national training 
guidelines and checklists for evaluating CLC staff competencies in 
each of the eight categories. The workgroup included representatives 
from Geriatrics and Extended Care, the Office of Nursing Services, 
[Footnote 21] Nutrition and Food Services,[Footnote 22] and the 
Infectious Diseases Program Office.[Footnote 23] A VA headquarters 
official told us that the workgroup included the last three offices 
because the majority of LTCI-identified deficiencies were related to 
nursing, nutrition, and infection control issues. VA headquarters 
provided the VA networks and CLCs with the national guidelines and 
checklists and required CLCs to incorporate them into their training 
and education policies. VA headquarters required CLCs to report 
whether they had met the following four requirements for each of the 
eight clinical high-risk categories: (1) establish CLC policies, (2) 
adopt procedures for implementing the policies,[Footnote 24] (3) 
design an assessment to observe staff proficiency in providing care 
matching the established procedure, and (4) establish a plan for 
ongoing training and assessment of staff, including new staff. 
[Footnote 25] In addition, CLCs were required to directly observe 
staff providing care to CLC residents and report the percentage of 
staff that had been observed as being proficient in the procedures 
necessary to comply with CLCs' policies for each of the eight clinical 
high-risk categories.[Footnote 26] If CLCs did not meet all four 
requirements for each category or had observed less than 90 percent of 
their staff as proficient in providing care in any one of the clinical 
high-risk categories, they were to develop and submit corrective 
action plans to VA headquarters. According to the documentation we 
reviewed, in most categories, the majority of CLCs indicated that they 
had met the requirements of the national training and education 
initiative. However, in every category there were CLCs that did not 
meet these requirements and had to submit a corrective action plan. 
For example, for the medication management clinical high-risk 
category, 14 of the 132 CLCs submitted a corrective action plan 
because they either were not in compliance with the four requirements 
or had not observed at least 90 percent of their staff as being 
proficient in providing care.[Footnote 27] 

After LTCI's 2010 and 2011 reviews of VA's CLCs are complete, VA 
headquarters plans to analyze the deficiencies identified by LTCI. To 
facilitate the analysis, VA headquarters is working with LTCI to track 
and note trends with regard to deficiencies on a quarterly basis. LTCI 
provides quarterly reports to VA headquarters, which include data on 
which deficiencies are the most frequently identified nationally. For 
each CLC, these reports include data on the total number of 
deficiencies identified and the categories in which the identified 
deficiencies fall. VA headquarters officials expect that these 
quarterly reports will facilitate the identification of national areas 
for improvement as well as help them review CLCs' performance on the 
LTCI reviews over time. 

VA Headquarters Cannot Provide Reasonable Assurance That All 
Deficiencies Are Resolved Because of Weaknesses in Its Process for 
Responding to Deficiencies: 

When responding to LTCI-identified deficiencies, VA headquarters does 
not always maintain clear and complete documentation of the feedback 
it provides to CLCs regarding their corrective action plans. In 
addition, VA headquarters does not require VA networks to report on 
the status of CLCs' implementation of their corrective action plans or 
to verify CLCs' self-reported compliance with the requirements of the 
national training and education initiative. Without the ability to 
determine whether CLCs appropriately responded to feedback, fully 
implemented their corrective action plans from the 2007 and 2008 LTCI 
reviews, or fully complied with requirements of the national training 
and education initiative, and without the ability to determine the 
status of corrective action plans that CLCs are implementing during 
LTCI's 2010 and 2011 reviews, VA headquarters does not have reasonable 
assurance that LTCI-identified deficiencies are resolved. 

Lack of clear and complete documentation of feedback. VA headquarters 
does not always maintain clear and complete documentation of the 
feedback it provides CLCs about their corrective action plans, which 
is not consistent with good management practices as outlined in 
federal internal control standards. According to these standards, 
internal control activities, such as VA headquarters' feedback, should 
be clearly and completely documented in a manner that is accurate, 
timely, and helps provide reasonable assurance that program objectives 
are being achieved.[Footnote 28] VA headquarters uses an unsystematic 
approach for documenting the feedback it provides to CLCs regarding 
their corrective action plans. The approach relies solely on hard 
copies of CLCs' action plans that have hand-written notes on them, 
which are not shared with the VA networks and CLCs, to document the 
feedback provided during VA headquarters' telephone calls with CLCs. 
We found that this approach did not always result in clear--that is, 
understandable to anyone not involved in the telephone feedback calls-
-and complete documentation. In particular, the documentation we 
reviewed did not always clearly and completely indicate the specific 
feedback provided to CLCs, including actions VA headquarters advised 
CLCs to take to address weaknesses with their corrective action plans. 
For example, for one CLC we obtained two corrective action plans from 
VA headquarters. One was an older action plan and the other was a 
revised action plan. The older action plan contained no notes or any 
indication of the content of VA headquarters' feedback that resulted 
in the revised action plan, so we were unable to independently 
determine whether the revised action plan addressed VA headquarters' 
feedback. In addition, we found that the plans for 19 of the 50 2007 
and 2008 CLC corrective action plans that we reviewed--or about 38 
percent of the plans--lacked any notes documenting the feedback that 
VA headquarters gave CLCs on the telephone calls. 

Lack of reporting requirement for VA networks. VA headquarters does 
not require its networks to report on the status of CLCs' 
implementation of their corrective action plans, and VA headquarters 
does not routinely schedule additional telephone calls with CLCs 
following the submission of initial corrective action plans and VA's 
initial telephone calls. For example, VA headquarters held additional 
telephone calls with only 25 percent of CLCs following the 2007 and 
2008 LTCI reviews, and 15 percent of the CLCs following the 2010 and 
2011 LTCI reviews, as of March 31, 2011. Therefore, VA headquarters 
does not know whether CLCs fully implemented their plans and corrected 
all LTCI-identified deficiencies. Federal standards for internal 
control state that the findings of reviews should be promptly resolved 
and that information on the status of the findings should be 
communicated to management so that management can provide reasonable 
assurance that a program is achieving its objectives--in this case, 
that CLCs are providing quality care and maintaining veterans' quality 
of life.[Footnote 29] VA headquarters officials told us that beyond 
the initial telephone calls with CLCs, VA headquarters does not 
receive any additional information from CLCs regarding the 
implementation status of their corrective action plans. Rather, VA 
headquarters officials expect the findings of the 2010 and 2011 LTCI 
reviews will help them determine whether CLCs resolved all 
deficiencies identified by LTCI in 2007 and 2008--2 or 3 years after 
the deficiencies were first identified. 

Lack of verification requirement for national initiative. We found 
that VA headquarters relied on self-reported information from CLCs 
regarding (1) compliance with all four requirements for each of the 
eight clinical high-risk categories and (2) the percentage of staff 
that were observed to be proficient in treatments and procedures 
associated with the categories. VA headquarters did not specify to its 
networks that they should verify the accuracy of CLCs' self-reported 
information. Reliance on self-reported information is inconsistent 
with federal standards for internal control specifying that management 
should be able to provide reasonable assurance about the accuracy of 
data--in this case, that VA networks verify the accuracy of CLCs' self-
reported information.[Footnote 30] Although we cannot generalize to 
all networks, neither of the two VA networks we visited requested 
documentation to verify CLCs' self-reported information for the 
national training and education initiative. Further, the 2010 and 2011 
LTCI reviews indicate that some CLCs are not in compliance with the 
requirements for the eight clinical high-risk categories stemming from 
the 2007 and 2008 reviews. For example, a CLC reported to VA 
headquarters that by June 2009 it would have a policy in place for 
training and educating its staff on PICC lines--one of the eight 
clinical high-risk categories. However, when LTCI reviewed this CLC in 
2010, it found that this CLC had failed to provide proper care and 
treatment when administering medication to a resident through a PICC 
line. When LTCI asked to see the CLC's policy related to PICC lines, 
the CLC's staff stated that the CLC did not have one. 

VA Headquarters Receives Information about CLCs from Multiple Sources, 
but Does Not Analyze It to Assess and Manage Risks: 

In addition to LTCI reviews, VA headquarters obtains information about 
CLCs from a variety of other sources that could be used to more 
comprehensively identify risks associated with the care and quality of 
life of CLC residents. VA headquarters does not analyze all of these 
sources, and for those sources it does analyze, VA evaluates each 
source in isolation without comparing the information it receives 
across all available sources to identify major or commonly cited risks 
and trends. As a result, VA headquarters' current approach to 
identifying risks in CLCs may result in missed opportunities to detect 
patterns and trends in information about the quality of care and 
quality of life within a CLC or across many CLCs. Without considering 
information from all available sources and comparing it across 
different sources, VA headquarters cannot adequately identify and 
manage risks in CLCs. 

VA Headquarters Receives Useful Information about CLCs from Multiple 
Sources: 

We found that VA headquarters receives information about the quality 
of care and quality of life in CLCs from at least nine different 
sources. The type of information VA headquarters receives from each of 
these sources, and how often the agency receives it, varies. The nine 
sources of information about CLCs are the following: 

* LTCI. Conducts annual unannounced reviews that assess the extent to 
which CLCs follow 176 federal long-term care standards.[Footnote 31] 
LTCI review teams observe the delivery of care for a sample of 
residents in order to examine such areas as medication management, 
infection control practices, and respect for residents' rights and 
dignity. LTCI provides VA headquarters a report of all deficiencies 
identified. VA headquarters then shares the report with the network 
and the reviewed CLC. The CLC is expected to correct identified 
deficiencies. 

* The Joint Commission. Performs accreditation surveys every 3 years, 
on average, assessing CLCs' compliance with 227 long-term care 
standards, such as infection control practices and resident 
assessments. When The Joint Commission surveyors find noncompliance, 
they determine whether a systemic problem exists by assessing the 
CLC's established policies and processes. This determination is the 
basis for whether CLCs are found deficient in a long-term care 
standard. VA networks and CLCs receive survey reports from The Joint 
Commission, which identify specific deficiencies. CLCs are required to 
resolve the deficiencies within certain time frames in order to 
maintain accreditation.[Footnote 32] 

* OIG. Performs its Combined Assessment Program reviews at VAMCs, 
including CLCs, about every 3 years. Under this program, OIG reviews 
selected VAMC activities, including CLC activities, to assess the 
effectiveness of patient care administration (the process of planning 
and delivering patient care) and quality management (the process of 
monitoring quality of care to identify and correct harmful and 
potentially harmful practices and conditions).[Footnote 33] CLCs 
typically are part of each Combined Assessment Program review. Upon 
completion of each review, OIG issues a report to VA headquarters, the 
network, and the VAMC, which identifies the VAMC's deficiencies, 
including any deficiencies identified in the CLC. VA requires VAMCs, 
including CLCs, to fully resolve deficiencies within a year of the 
completion of a Combined Assessment Program review. 

* VA Office of the Medical Inspector (OMI). Conducts investigations to 
determine the validity of allegations made by complainants regarding 
the care provided to veterans, including residents of CLCs.[Footnote 
34] If an allegation is validated, the VAMC, including the CLC, is 
required to address any recommendations made by OMI.[Footnote 35] 

* System-wide Ongoing Assessment and Review Strategy (SOARS). Performs 
reviews of VAMCs, including CLCs, every 3 years to evaluate readiness 
for some external and internal reviews, such as those by The Joint 
Commission and OIG.[Footnote 36] It is a consultative program within 
VA designed to identify programmatic weaknesses in VAMCs, including 
CLCs. SOARS teams issue reports to VA networks and VAMCs, including 
CLCs, with recommendations based on identified deficiencies, and VAMCs 
and CLCs are expected to implement the recommendations. 

* Quality Measures and Quality Indicators. Report the percentage of 
residents in a CLC who have certain conditions, such as a pressure 
ulcer, or residents who are at risk for developing certain conditions, 
such as CLC residents who have limited mobility and are at risk of 
developing a pressure ulcer. CLCs periodically assess residents and 
enter information about their conditions into a database, which 
automatically calculates percentage scores for 24 categories of 
quality measures and quality indicators. Data are available on an 
ongoing basis. 

* Artifacts of Culture Change Tool.[Footnote 37] Reports the extent to 
which CLCs provided resident-centered care. Using a standard self- 
assessment tool, CLCs score their own performance in certain areas, 
such as allowing residents to choose when they eat meals, bathe, and 
sleep. CLCs report their scores to VA headquarters every 6 months. 

* Issue Briefs. Provide specific information to VA headquarters 
officials regarding unusual incidents, such as deaths, disasters, or 
anything else that happens at a VAMC, including a CLC, that might 
generate media interest or affect care.[Footnote 38] 

* Complaints. Provide information from veterans or their 
representatives about the quality of care or the quality of life in 
VAMCs, including CLCs.[Footnote 39] 

VA Headquarters Does Not Consider the Potential Usefulness of All 
Available Information to Assess and Manage Risks in CLCs: 

VA headquarters' approach for identifying risks associated with the 
quality of care and quality of life of CLC residents is deficient in 
two respects--it does not comprehensively analyze information from all 
available sources, and it does not compare findings across these 
sources. Without analyzing information from all available sources and 
comparing the results, VA headquarters' assessments of risks in CLCs 
are incomplete. According to federal internal control standards, 
management should assess the risks the agency may face from both 
external and internal sources. The standards state that a risk 
management process includes (1) comprehensively identifying risks 
associated with achieving an agency's goals (for example, providing 
quality of care and quality of life in CLCs); (2) estimating the 
significance of the risks; and (3) determining actions to mitigate the 
risks, such as developing or clarifying policies or targeting reviews 
of noncompliant CLCs.[Footnote 40] 

VA Headquarters Does Not Analyze Information from All Available 
Sources: 

VA headquarters' current approach relies significantly on the analysis 
of findings from LTCI reviews of CLCs. VA headquarters also relies on 
analysis of the findings from The Joint Commission accreditation 
surveys and the Artifacts of Culture Change tool. (See app. I for a 
detailed description of these analyses.) While these three separate 
analyses enable VA headquarters to identify trends in each source of 
information, such as the most frequently cited deficiencies across all 
CLCs or the average number of deficiencies per CLC, they do not 
provide a complete assessment of the risks that would be identified by 
evaluating all nine sources. Information VA headquarters receives 
about the quality of care and the quality of life in CLCs from the 
remaining six sources--OIG, OMI, SOARS, quality measures and quality 
indicators, issue briefs, and complaints--could also be valuable in 
identifying patterns in CLC-related findings. VA headquarters 
officials we interviewed said they do not typically analyze 
information they receive about CLCs from these six sources because 
they do not always believe that doing so would be valuable for 
identifying trends and patterns regarding the quality of care and 
quality of life in CLCs. For example, VA headquarters officials said 
that they do not extract CLC-related findings from OIG Combined 
Assessment Program reviews because the reviews typically do not 
include enough CLC-related findings to warrant analysis. However, when 
we analyzed findings from the 77 OIG Combined Assessment Program 
reviews that were completed at VAMCs that have CLCs between October 1, 
2009, and June 20, 2011, we found that 49 of the reviews--or about 64 
percent--included at least one finding related to the quality of care 
or quality of life in a CLC. Without analyzing information from all 
available sources about the quality of care and quality of life in 
CLCs, VA headquarters' assessments of risks in CLCs are incomplete. 

VA Headquarters Does Not Compare Information across All Available 
Sources: 

VA headquarters does not compare information across all sources to 
identify patterns of findings for an individual CLC, CLCs within a 
network, or all CLCs nationwide. Rather, VA headquarters analyzes the 
findings from three sources separately to identify trends in the 
findings. However, it does not compare the findings from one source to 
the findings from the other sources. One source's findings, in 
isolation, may not present the significance of certain risks, 
especially those that may suggest immediate risks for residents within 
a given CLC or across all CLCs. However, if related information that 
VA headquarters receives was compared across different sources 
concurrently, VA headquarters officials would be better positioned to 
recognize the risks to CLC residents. 

One example we identified of the benefit from considering the 
usefulness of multiple information sources is in the area of pain 
management. In this regard, we found that in fiscal years 2009 and 
2010, VA headquarters' quality indicator and quality measure data 
showed that about 25 percent of all long-stay CLC residents and 40 
percent of all short-stay CLC residents experienced moderate to severe 
pain. In June 2007, OMI investigated allegations about the quality of 
care for a resident at one CLC and found, among other things, that the 
CLC had failed to adequately manage the resident's pain. Three months 
later, in September 2007, LTCI conducted a review of the same CLC and 
found that staff were not performing assessments after administering 
pain medications to determine whether the medication had been 
effective. In November 2009, the OIG visited the same CLC as part of a 
Combined Assessment Program review and found that staff had not 
documented pain medication effectiveness within the required time 
frames nearly two-thirds of the time that pain medications were 
administered. If VA had comprehensively analyzed OMI information--
which it does not analyze--along with LTCI information that was 
available in 2007 and compared this information with the information 
from the 2009 OIG review and quality indicator and quality measure 
data, VA headquarters would have been better informed about the 
significance of the risks and what actions might have helped to 
mitigate the risks of pain medication management problems at this CLC. 

Conclusions: 

The 46,000 elderly and disabled veterans annually who are residents in 
VA's CLCs depend on VA to provide them with quality care and maintain 
their quality of life. The weaknesses in VA headquarters' process for 
resolving LTCI-identified deficiencies put veterans at risk of 
persistent deficiencies that could become more serious over time. VA 
headquarters officials told us that they intend to use the findings of 
the 2010 and 2011 LTCI reviews to determine whether deficiencies that 
were first identified by LTCI 2 to 3 years earlier have been resolved. 
However, VA headquarters cannot provide reasonable assurance of 
resolution of deficiencies because it does not (1) clearly document 
the feedback that it provides to CLCs about corrective action plans 
for LTCI-identified deficiencies, (2) require VA networks to report on 
the status of CLCs' implementation of action plans, and (3) verify 
CLCs' self-reported information about their implementation of the 
requirements of the national training and education initiative. 
Unaddressed, these weaknesses in VA headquarters' process for 
responding to LTCI-identified deficiencies may compromise the quality 
of care and quality of life of veterans in CLCs. 

Even though VA headquarters receives information about the quality of 
care and quality of life in CLCs from LTCI and a variety of other 
sources, the agency does not comprehensively analyze all available 
information to identify and manage risks in CLCs. Because VA 
headquarters does not analyze information from all available sources, 
it may be missing opportunities to detect trends and patterns in 
findings from different information sources for a CLC, CLCs within a 
network, or all CLCs. Without comprehensively analyzing information 
from all available sources, VA headquarters cannot fully identify 
risks in CLCs, estimate the significance of the risks, or take actions 
to mitigate them. 

Recommendations for Executive Action: 

To provide reasonable assurance that LTCI-identified deficiencies are 
resolved and that veterans receive quality care and maintain their 
quality of life in VA CLCs, we recommend that the Secretary of 
Veterans Affairs direct the Under Secretary for Health to take the 
following two actions: 

* For reviews conducted by LTCI under the current contract and any 
similar future contracts, (1) clearly and completely document the 
feedback provided to CLCs about their corrective action plans, (2) 
require VA networks to provide periodic reports on the status of CLCs' 
implementation of their corrective action plans, and (3) develop and 
implement a process for verifying any information reported directly to 
VA headquarters by CLCs. 

* Develop and implement a process to comprehensively identify, 
estimate, and mitigate risks in CLCs by analyzing and comparing all 
available information regarding the quality of care and quality of 
life in CLCs. 

Agency Comments and Our Evaluation: 

In its comments on a draft of this report, VA concurred with our 
recommendations and described the department's planned actions to 
implement them. VA did not provide technical comments on the draft 
report. VA's comments are included in appendix II. 

To address our recommendation that, for reviews conducted by LTCI, VA 
headquarters should document the feedback provided to CLCs about their 
corrective action plans, require VA networks to report periodically on 
the status of CLCs' implementation of corrective action plans, and 
implement a process for verifying information CLCs report directly to 
VA headquarters, VA stated that it plans to develop and implement a 
national feedback process by the end of the second quarter of fiscal 
year 2012 as part of its response to results from the LTCI reviews. VA 
stated that the process will include having VA networks work with VAMC 
leadership to develop a comprehensive action plan to address areas of 
concern highlighted in the LTCI reviews, using a standardized template 
for CLCs' corrective action plans, and requiring VAMCs to post 
corrective action plans on a secure database and provide updated 
corrective action plans at least monthly. VA indicated that the 
process will provide access to the status of action plans at any time 
and that officials from VA headquarters will provide oversight to 
ensure completion of action plans, including requiring VA networks to 
validate completion of all action items. VA, however, did not specify 
in its comments whether its process would include a step to document 
the feedback provided to CLCs about their corrective actions plans. We 
believe it is important for VA to document feedback provided to CLCs 
as part of its process: 

To address our recommendation that VA headquarters develop and 
implement a process to comprehensively identify, estimate, and 
mitigate risks in CLCs by analyzing and comparing all available 
information regarding quality of care and quality of life, VA stated 
that it plans to design a process that will use all available 
information about the quality of care and quality of life in CLCs. VA 
indicated that this process would allow officials to analyze and 
compare information for individual CLCs, for CLCs within a VA network, 
and across all CLCs nationwide. VA intends to design this process 
during the first quarter of fiscal year 2012 and plans to use the 
process to analyze and compare CLC information and begin reporting it 
during the second quarter of fiscal year 2012. We commend this effort 
and encourage VA to proceed with these plans. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the 
Secretary of Veterans Affairs, appropriate congressional committees, 
and other interested parties. In addition, the report will be 
available at no charge on the GAO website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-7114 or williamsonr@gao.gov. Contact points 
for our Offices of Congressional Relations and Public Affairs are on 
the last page of this report. GAO staff who made major contributions 
to this report are listed in appendix III. 

Sincerely yours, 

Signed by: 

Randall B. Williamson: 
Director, Health Care: 

[End of section] 

Appendix I: VA Headquarters' Analysis of Information about the Quality 
of Life and Care in Community Living Centers: 

Source of information: Long Term Care Institute, Inc; 
Frequency of analysis: Quarterly, annually; 
Description of VA headquarters analysis: 
* Identify the most frequently cited deficiencies nationally; 
* Identify the total number of deficiencies per community living 
center (CLC); 
* Classify deficiencies identified in each CLC into 1 of 17 different 
groups (e.g., activities, environment, infection control, medication, 
etc.). Use these groups to track trends in deficiencies by VA network 
and by CLC; 
* Determine whether each CLC was substantially compliant with federal 
long-term care standards. 

Source of information: The Joint Commission; 
Frequency of analysis: Annually; 
Description of VA headquarters analysis: 
* Identify most frequently cited findings for two areas:[A]; 
1. Direct impact: includes findings that are likely to present an 
immediate risk to residents' safety or quality of care; for example, 
resident assessment and pain management; 
2. Indirect impact: includes findings that pose less immediate risk to 
residents' safety or quality of life, but could become more serious 
over time; for example, care planning and ensuring that corridors, 
hallways, and doors remain free from obstructions that would prevent 
exit in the event of a fire; 
* Calculate average number of findings per CLC. 

Source of information: Quality measures and quality indicators; 
Frequency of analysis: Quarterly, annually; 
Description of VA headquarters analysis: 
* Calculate average performance on 30 measures and indicators, by VA 
network and nationally; 
for example, percentage of long-stay residents who have experienced 
moderate to severe pain. 

Source of information: Artifacts of culture change tool; 
Frequency of analysis: Every 6 months; 
Description of VA headquarters analysis: 
* Calculate average scores, by VA network and nationally, for areas 
such as care practices (e.g., allowing residents to choose when they 
eat, bathe, and sleep) and leadership (e.g., holding regular community 
meetings that encourage the participation of staff, residents, and 
families). 

Source: GAO analysis of VA data. 

[A] In its surveys, The Joint Commission determines whether findings 
have a direct or an indirect impact on resident care. 

[End of table] 

[End of section] 

Appendix II: Comments from the Department of Veterans Affairs: 

Department Of Veterans Affairs: 
Washington DC 20420: 

October 11, 2011: 

Mr. Randall Williamson: 
Director, Health Care: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Williamson: 

The Department of Veterans Affairs (VA) has reviewed the Government
Accountability Office's (GAO) draft report, "VA Community Living 
Centers: Actions Needed to Better Manage Risks to Veterans' Quality of 
Care and Quality of Life," (GAO-12-11) and is providing comments in 
the enclosure. 

VA appreciates the opportunity to comment on your draft report. 

Sincerely, 

Signed by: 

John R. Gingrich: 
Chief of Staff: 

Enclosure: 

[End of letter] 

Enclosure: 

Department of Veterans Affairs (VA) Comments to Government 
Accountability Office (GAO) Draft Report: VA Community Living Centers: 
Actions Needed to Better Manage Risks to Veterans' Quality of Care and 
Quality of Life (GAO-12-11): 

GAO Recommendation: To provide reasonable assurance that LTCI-identified
deficiencies are resolved and that veterans receive quality care and 
maintain quality of life in VA CLCs, we recommend that the Secretary 
of Veterans Affairs direct the Under Secretary for Health to take the 
following two actions: 

Recommendation 1: For reviews conducted by LTCI under the current 
contract and any similar future contracts, (1) clearly and completely 
document the feedback provided to CLCs about their corrective action 
plans, (2) require VA networks to provide periodic reports on the 
status of CLCs' implementation of their corrective action plans, and 
(3) develop and implement a process for verifying any information 
reported directly to VA headquarters by CLCs. 

VA Comment: Concur. The Veterans Health Administration, Deputy Under 
Secretary for Operations and Management (DUSHOM) in collaboration with 
the Deputy Under Secretary for Policy and Services (DUSH/PS) will 
provide leadership and oversight for the development and execution of 
a process designed to provide continuous national feedback in response 
to Long Term Care Institute (LTCI) community living centers (CLC) 
review results. This process will be fully operational by the end of 
2nd quarter fiscal year (FY) 2012. The process will include, but not 
be limited to: 

1) Veterans Integrated Service Network (VISN) Chief Medical 
Officers/Quality Management Officers working with VA medical center 
(VAMC) leadership to develop a comprehensive action plan to address 
areas of concern obtained in the feedback from a LTCI review; 

2) Using a standardized action plan template to outline corrective 
action plans; 

3) VAMCs placing final action plans on a secured Sharepoint site that 
will automatically notify the Offices of Geriatrics and Extended Care 
(GEC) in the Offices of the DUSHOM and DUSH/PS; 

4) Requiring VAMCs to update action plans at least monthly; 

5) The GEC operations and policy offices briefing the Assistant Deputy 
Under Secretary for Health for Policy and Services (ADUSH/PS) and the 
ADUSH for Clinical Operations quarterly on the status of all action 
plans; 

6) The ADUSH offices providing oversight to ensure completion of plans 
of action. 

This process provides access to status of actions plans at any point 
in time for review and action, as well as planned quarterly reviews 
and briefings with yearly surveys to determine overall effectiveness 
of process and national outcomes. VISNs will validate the completion 
of all action items. The findings of the contract CLC Yearly Survey 
outcomes will serve to validate the success of action plans. 

Recommendation 2: Develop and implement a process to comprehensively 
identify, estimate, and mitigate risks in CLCs by analyzing and 
comparing all available information regarding the quality of care and 
quality of life in CLCs. 

VA Comment: Concur. The GEC Offices in the Offices of the DUSHOM and 
DUSH/PS will collaborate with the Office of the Assistant Deputy Under 
Secretary for Informatics and Analytics to design a process to 
comprehensively identify, estimate, and mitigate risks in CLCs by 
analyzing and comparing all available information regarding the 
quality of care and quality of life in CLCs. 

The process will support continuous data collection and quarterly 
analysis, including the ability to identify trends at the VAMC, VISN 
and national levels. The target for completion of the process is the 
end of FY 2012, quarter 1, with the first report generation planned 
for FY 2012, quarter 2. The GEC offices will brief the DUSH/PS and 
DUSHOM about the analysis of information about outcomes of care and 
quality of life for residents in CLCs on a quarterly basis. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Randall B. Williamson, (202) 512-7114 or williamsonr@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Mary Ann Curran, Assistant 
Director; Stella Chiang; Julie Flowers; Alison Goetsch; Aaron Holling; 
Alexis MacDonald; Elizabeth Morrison; and Lisa Motley were major 
contributors to this report. 

[End of section] 

Related GAO Products: 

VA Long-Term Care: Trends and Planning Challenges in Providing Nursing 
Home Care to Veterans. [hyperlink, 
http://www.gao.gov/products/GAO-06-333T]. Washington, D.C.: January 9, 
2006. 

VA Long-Term Care: Oversight of Nursing Home Program Impeded by Data 
Gaps. [hyperlink, http://www.gao.gov/products/GAO-05-65]. Washington, 
D.C.: November 10, 2004. 

[End of section] 

Footnotes: 

[1] The remaining $1.2 billion spent for nursing home care was for 
care provided to veterans in state veterans homes ($652 million) and 
community nursing homes ($550 million). 

[2] VA's model of care for CLC residents emphasizes the delivery of 
quality health care and the maintenance of a quality of life for CLC 
residents. Practices that contribute to residents' quality of life 
include the extent to which CLC staff treat residents with respect and 
dignity and the extent to which residents are permitted to exercise 
personal preferences in areas such as the activities they choose to 
engage in and the food they choose to eat. See Veterans Health 
Administration Handbook 1142.01, Criteria and Standards for VA 
Community Living Centers (Aug. 13, 2008). 

[3] LTCI is a not-for-profit organization that surveys nursing homes 
and other residential settings to improve care for residents. 

[4] VA had no in-depth reviews of CLCs conducted between October 2008 
and September 2010. 

[5] The 50 corrective action plans we reviewed were submitted by CLCs 
that were reviewed by LTCI in 2007 or 2008 and again between September 
1, 2010, and March 31, 2011. We chose March 31, 2011, as the final 
date for inclusion in our sample of 2010 and 2011 LTCI reviews and 
corrective action plans because VA headquarters requires that LTCI 
provide a final report 10 days after the completion of an LTCI review. 
VA headquarters then transmits the review to the CLC, which has up to 
30 days to submit its corrective action plan to VA headquarters. Given 
the time frames within which we could reasonably expect to receive 
copies of the 2010 and 2011 LTCI reviews and action plans from VA 
headquarters, we chose to limit the scope of our sample to LTCI 
reviews that were completed before March 31, 2011. 

[6] The corrective action plans and related documentation of the 23 
CLCs represent all of the 2010 and 2011 action plans that were 
available as of March 22, 2011. These 23 CLCs represent about 34 
percent of the CLCs included in our sample of LTCI reviews that were 
completed, as of March 31, 2011. Findings from our review of the 
sample of 2007 and 2008 corrective action plans, along with findings 
from our review of the sample of 2010 and 2011 LTCI reviews and 
corrective action plans, cannot be generalized to all CLCs. 

[7] In this report, we use Geriatrics and Extended Care when referring 
to the Office of Geriatrics and Extended Care. 

[8] We selected the VA Mid-Atlantic Health Care Network because it had 
a high average number of deficiencies per CLC. We selected the VA 
Northwest Health Network because it had a medium average number of 
deficiencies per CLC. 

[9] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[10] VA nursing home care is provided in three settings: VA-operated 
CLCs, community nursing homes, and state veterans homes. 

[11] 38 U.S.C. § 1710A(a). These requirements will terminate on 
December 31, 2013. 38 U.S.C. § 1710A(d). The statute states that these 
requirements may not be construed as authorizing or requiring that a 
veteran who was receiving nursing home care in a department nursing 
home on November 30, 1999, be displaced, transferred, or discharged 
from the facility. 38 U.S.C. § 1710A(b)(2). Requirements for the 
provision of nursing home care, like those related to hospital and 
medical care, are effective in any fiscal year only to the extent and 
in the amount provided in advance in appropriations acts for such 
purposes. 38 U.S.C. § 1710(a)(4). 

[12] 38 U.S.C. § 1710(a)(2), (3). 

[13] In August 2011, VA exercised its option for a second year for 
reviews to be conducted from September 2011 through August 2012. The 
cost of the contract for the base year was $3.5 million. If VA 
exercises all of the options through 2015, the total cost of the 
contract for 5 years will be $18.3 million. 

[14] See Veterans Health Administration Handbook 1100.16, 
Accreditation of Veterans Health Administration Medical Facility and 
Ambulatory Programs (Sept. 22, 2009). The Joint Commission is an 
independent organization that accredits and certifies health care 
organizations and programs in the United States. 

[15] Community nursing homes that receive Medicare or Medicaid 
payments must be inspected by state agencies that contract with the 
Centers for Medicare & Medicaid Services not later than 15 months 
after the date of the previous inspection, and the statewide average 
for inspection of nursing homes must not exceed 12 months. See 42 
U.S.C. §§ 1395i-3(g)(2)(A)(iii), 1396r(g)(2)(A)(iii). Community 
nursing homes are evaluated on compliance with federal long-term care 
standards, which are codified at 42 C.F.R. Part 483, Subpart B. 
Community nursing homes may separately contract with The Joint 
Commission to receive accreditation, although this is not a 
requirement for receiving Medicare or Medicaid payment. 

[16] See Veterans Health Administration Handbook 1142.01, Criteria and 
Standards for VA Community Living Centers (Aug. 13, 2008). 

[17] The 29 CLCs that participated in more than one telephone call 
with VA headquarters after their 2007 or 2008 review were located in 
16 of VA's 21 networks. 

[18] For immediate jeopardy level findings, LTCI surveyors are 
required to remain at the CLC until the deficiencies are abated. 

[19] To be consistent with criteria used by VA in requiring 
notification of immediate jeopardy and actual harm deficiencies, our 
analysis did not include deficiencies classified as isolated actual 
harm. According to a VA headquarters official, deficiencies classified 
as isolated actual harm were not included in the criteria due to their 
limited scope. 

[20] A central line is a small tube that is placed in a large vein in 
the neck, chest, groin, or arm to give fluids, blood, or medications 
or to do medical tests quickly. A central line can remain for weeks or 
months, and some patients receive treatment through the line several 
times a day. A PICC line is a specific type of central line that is 
placed into a vein in the arm. 

[21] The Office of Nursing Services is responsible for devising 
policies on all issues related to nursing practice and nursing 
workforce for VA's clinical programs, including nurses in CLCs. 

[22] Nutrition and Food Services is responsible for providing overall 
policy, guidelines, and program development relevant to each health 
care system and medical center's nutrition and food services. 

[23] The Infectious Diseases Program Office is responsible for 
assisting and developing policy, guidelines, and program development 
for infectious diseases clinical programs, infection prevention and 
control, and the infectious diseases health science policy and 
epidemiology program. 

[24] For example, the procedures adopted could include those in the 
Lippincott Manual of Nursing Practice, which is a manual that outlines 
clinical guidelines and procedures for nursing practice. 

[25] In 2009, VA headquarters specified these requirements in three 
memorandums from VA's Deputy Under Secretary for Health for Operations 
and Management. The memorandums were dated January 28, 2009; April 23, 
2009; and October 15, 2009. VA required CLCs to submit these eight 
checklists during calendar years 2009 and 2010. 

[26] The requirements for the national training and education 
initiative were applicable to all 132 CLCs, including the 16 CLCs that 
LTCI did not review in 2007 and 2008. 

[27] The corrective action plans for the clinical high-risk categories 
were separate from the corrective action plans that all CLCs had to 
submit directly in response to the LTCI-identified deficiencies. 

[28] Control activities are the policies, procedures, techniques, and 
mechanisms that help ensure that an agency's directives are carried 
out and that the agency accomplishes its objectives. See [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[29] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[30] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[31] These are the same long-term care standards used by the Centers 
for Medicare & Medicaid Services for certifying community nursing 
homes for participation in the Medicare and Medicaid programs. See 42 
C.F.R. Part 483, Subpart B (2010). Every nursing home receiving 
Medicare or Medicaid payment must be evaluated on these long-term care 
standards not later than 15 months after the date of the previous 
evaluation, and the statewide average for these evaluations must not 
exceed 12 months. See 42 U.S.C. §§ 1395i-3(g)(2)(A)(iii), 
1396r(g)(2)(A)(iii). 

[32] The Joint Commission has established timelines based on whether a 
deficiency is considered directly or indirectly related to patient 
care. Deficiencies directly related to patient care must be resolved 
within 45 days. Deficiencies indirectly related to patient care must 
be resolved within 60 days. 

[33] The activities selected as topics of the Combined Assessment 
Program reviews change every 6 to 12 months. According to OIG 
officials, the selection of activities is based on various internal 
and external factors: (1) past experience of Combined Assessment 
Program review team members, (2) trends identified from the OIG 
complaint system, and (3) problems identified in the private sector 
(e.g., past concerns regarding the availability of flu vaccines). 

[34] Between November 2007 and June 2011, OMI conducted a total of 
five investigations concerning incidents in CLCs. 

[35] Officials from VA networks and VA headquarters are responsible 
for ensuring that VAMCs, including CLCs, have adequately addressed 
recommendations made by OMI. 

[36] SOARS identifies 28 areas in which a VAMC may be reviewed based 
on 100 different VA-defined criteria. 

[37] Culture change refers to efforts to transform the culture of 
nursing home care from a medical model, where care is driven by a 
medical diagnosis, to a person-centered model, where care is driven by 
the needs of the individual, as affected by medical conditions. The 
goals of care are achieved in an environment where the resident is 
respected, treated with dignity, and invited to be an active 
participant in the resident's own care. See Veterans Health 
Administration Handbook 1142.01, Criteria and Standards for VA 
Community Living Centers (Aug. 13, 2008). 

[38] Instances that may trigger an issue brief include a homicide or 
suicide on VA property, significant clinical incidents or outcomes 
negatively affecting a veteran or group of veterans, or a breach of 
information security. 

[39] These complaints are separate from allegations submitted to OMI. 

[40] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[End of section] 

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