Phase 2 Requirements of Participation for Nursing Homes are Coming Soon!

Revised Requirements of Participation for skilled nursing facilities were released on June 30, 2017.  The latest update of the State Operations Manual can be found here.

The interpretive guidelines effective November 28, 2017, include clarifications to current regulations, Phase 2 requirements, and information on the revised survey process and protocols.

Phase 2 is less than four months away leaving providers feeling overwhelmed and ill prepared for the next phase of implementation.  To complicate things even further, we now have Emergency Preparedness due November 15th, 2017 and a new survey process with new F-Tags.  There is only so much time to learn and prepare for all of this. However, Pathway Health is here to help wherever possible. Our comprehensive education and consultation division can provide you with all the tools you need to work through and implement these changes.

New F-Tags

The F-Tags are renumbered starting with F550 and ending currently at F949.  The F-Tags are not a direct renumbering from the previous F-Tags.  New F-Tags have been added, some tags are combined and others separated.  It will take time to read and understand the new regulatory groups and what tags fit into each one.


New Survey Process

Effective November 28, 2017, CMS will utilize the revised interpretive guidance to survey skilled nursing facilities under a new process.  The new survey process will be a combination of the Quality Indicator Survey process and the traditional process.  For providers that are currently surveyed under the traditional process, there will be a learning curve to get up to speed with how the QIS survey process works.  For those who already have QIS in their states, the transition may be a bit easier because they have experienced both.  Many staff have not experienced both so education on survey readiness will be key to the success of an organization’s survey process.


Enforcement and Nursing Home Compliance

The regulations for Phase 2 will go into effect as planned on November 28, 2017, with no delays.  CMS has heard concerns from providers regarding the ability to fully implement these regulations and the risk for civil money penalties, denial of payment, or termination of certification. Due to these concerns, CMS will provide a one year restriction of enforcement remedies for specific Phase 2 requirements.  They will not impose civil money penalties or other enforcement remedies but instead required directed plans of correction or directed education and training.  “Directed” means that an outside third party will need to be engaged to assist the facility with compliance.

How to be Prepared?

If the above seems impossible, let us help you.  Pathway Health has a comprehensive education and consultation division that will provide you the education, tools, resources, and consulting partnership you need to be successful under the new regulations.  We are the friendly face to regulations!  Don’t wait. Take action now and be ready!