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 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.