CMS SOM App. PP, Tag F687

To ensure that residents receive proper treatment and care to maintain mobility and

good foot health, the facility must:

(i) Provide foot care and treatment, in accordance with professional standards of

practice, including to prevent complications from the resident’s medical

condition(s) and

(ii) If necessary, assist the resident in making appointments with a qualified

person, and arranging for transportation to and from such appointments.

INTENT

To ensure that the foot care provided is consistent with professional standards of practice

and to clarify that foot care includes treatment to prevent complications from conditions

such as diabetes, peripheral vascular disease, or immobility. Also includes assisting the

resident in making necessary appointments with qualified healthcare providers such as

podiatrists and arranging for transportation to and from such appointments.

GUIDANCE

Facilities are responsible for providing the necessary treatment and foot care to residents.

Treatment also includes preventive care to avoid podiatric complications in residents with

diabetes and circulatory disorders who are prone to developing foot problems. Foot care

that is provided in the facility, such as toe nail clipping for residents without complicating

disease processes, should be provided by staff who have received education and training

to provide this service. Foot care and treatment must be provided within professional

standards of practice and state scope of practice, as applicable.

Residents requiring foot

care who have complicating disease processes must be referred to qualified professionals

such as those listed as examples below.

Facilities are also responsible for providing residents access to qualified professionals

who can treat foot disorders, by making necessary appointments and arranging

transportation. Examples include podiatrist, Doctor of Medicine, and Doctor of

Osteopathy. Foot disorders which may require treatment include, but are not limited to:

corns, neuromas, calluses, hallux valgus (bunions), digiti flexus (hammertoe), heel spurs,

and nail disorders. The facility is also responsible for assisting residents in making

appointments and arranging transportation to obtain needed services.

Facility staff must follow proper infection prevention practices for foot care

equipment/devices, including but not limited to nail clippers, scalers, files, and burr tools.

Facility staff must separate used or contaminated foot care equipment from clean

equipment. Reusable medical devices (e.g., scalers, electronic nail file, and surgical

instruments) that are used on one resident must be cleaned and reprocessed (disinfection

or sterilization) for use according to manufacturer’s instructions prior to use on another

resident. If the manufacturer does not provide such instructions, the device may not be

suitable for multi-patient use. Recommendations for the cleaning, disinfection, and

sterilization of medical devices are available in CDC’s Guideline for Disinfection and

Sterilization in Healthcare Facilities

, 2008 (available at:

https://www.cdc.gov/infectioncontrol/guidelines/disinfection/index.html). Please see

guidance at §483.80, Infection Control, for more information.

NOTE: For purposes of this guidance, “staff” includes employees, the medical director,

podiatrists, consultants, contractors, and volunteers. Staff would also include caregivers

who provide care and services to residents on behalf of the facility, students in the

facility’s nurse aide training program, and students from affiliated academic institutions,

including therapy, social, and activity programs.

PROBES: For residents selected for review, determine the following:

• According to the medical record, does the resident have a diagnosis or condition

that poses a risk to foot health (e.g., diabetes, peripheral vascular disease, ingrown

toenails)?

• Does the comprehensive care plan adequately address the resident’s risk with

appropriate interventions?

• Observe residents’ feet for lack of nail care, presence of calluses, and/or other

foot problems.

• Are residents with foot concerns seen either within the facility or community by a

qualified foot care specialist? Do residents with mobility concerns have foot care

concerns, and did the facility address these concerns?

• Are qualified healthcare providers available to see residents either in the facility

or in the community?

• What preventive foot care do staff provide and to what resident population?

• Are staff providing foot care to the resident when needed and ordered?

• Do staff maintain separation of clean and contaminated podiatry equipment? If

no, refer to §483.80, Infection Control F880.