Trauma-Informed Care: Understanding the Terms
Jeannine LeCompte, Compliance Research Specialist
“Trauma-informed care” forms one part of the Centers for Medicare & Medicaid Services’ (CMS) Phase 3 changes which come into effect November 28, 2019. It is important that all long-term care (LTC) facilities are prepared and management have a clear understanding of what is required.
The “trauma” requirements are contained in Title 42 of the Code of Federal Regulations (CFR) §483.25, and paragraph “m” in particular. §483.25 states that it will be a requirement of all LTC facilities to provide residents with the “necessary care and services to attain or maintain the highest practicable physical, mental, and psychosocial well-being, in accordance with the comprehensive assessment and plan of care.”
Paragraph (m), “trauma-informed care,” states that facilities must “ensure that residents who are trauma survivors receive culturally-competent, trauma-informed care in accordance with professional standards of practice and accounting for residents’ experiences and preferences in order to eliminate or mitigate triggers that may cause re-traumatization of the resident.” Failure to adhere to these guidelines can lead to penalties and have financial implications.
To understand this requirement it is helpful to know the definitions of “trauma,” “culturally competent care,” and “trauma-informed care.”
According to the Merriam-Webster dictionary, trauma is defined as “a: an injury (such as a wound) to living tissue caused by an extrinsic agent; b: a disordered psychic or behavioral state resulting from severe mental or emotional stress or physical injury; or c: an emotional upset.” It is clear from this definition that the CMS rule is referring to the last two meanings: a psychological state of being.
Psychological disturbance caused by trauma can result from life events, or even from being put into an LTC facility. Life events can be any set of circumstances out of the ordinary. What constitutes ordinary can of course be different depending on the individual.
It is the variable nature of what constitutes “trauma” which makes the application of suitable care such a complex procedure. For example, a particular Vietnam veteran might be a perfectly well-adjusted individual, but another might be suffering severe psychological trauma dating from his wartime experiences.
The CMS rule requires LTC facilities to have a mechanism in place to deal with these individuals who are suffering from trauma. The requirement that residents be treated with “culturally competent care” means that, in addition to the above, LTC staff must also have the ability to interact effectively with people of different cultures.