S&C Letter Updates W187 Staffing Guidance

The ICF/IID Interpretive Guidance was recently revised on February 27, 2015 to acknowledge and address current standards of practice in the field of ICF/IIDs with an effective and implementation date of April 27, 2015.  In the revision process, the guidance associated with regulation §483.430(d)(3) at tag W187 was erroneously revised and omitted important and relevant guidance.

The guidance added on February 27, 2015 associated with the above referenced regulation §483.430(d)(3) at Tag W187 has been revised now to reinstate the previous guidance as follows:

“The minimum ratios in this standard indicate the minimum number of direct-care staff that must be present and on duty, 24 hours a day, 365 days a year, for each discrete living unit.  For example, to calculate the minimum number of living unit staff that must be present and on duty in a discrete living unit serving 16 individuals with multiple disabilities:  divide the number of individuals “16,” by the number corresponding to the regulation “3.2,” the result equals “5.”  Therefore, the facility must determine how many staff it must hire to ensure that at least 5 staff will be able to be present and on duty during the 24 hour period in which those individuals are present.

Using the living unit described above, “calculated over all shifts in a 24-hour period” means that there are present and on duty every day of the year:  one direct care staff for each eight individuals on the first shift (1:8), one direct care staff for each eight individuals on the second shift (1:8), and one direct care staff for each 16 individuals on the third shift (1:16).  Therefore, there are five (5) direct care staff present and on duty for each twenty-four hour day, for 16 individuals.  The same calculations are made for the other ratios, whichever applies.  Determine if absences of staff for breaks and meals results in a pattern of prolonged periods in which present and on-duty staff do not meet the ratios.”

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