CMS Releases Nursing Home Survey Guidance for Phase 3 Requirements

On June 29, the Centers for Medicare and Medicaid Services (CMS) released long-awaited updates to the nursing home surveyor guidance found in Appendix PP to the State Operations Manual.

QSO Memorandum 22-19-NH and this fact sheet provide high-level summaries of what CMS has released, which includes clarifications and technical corrections of Phase 2 guidance issued in 2017 and new guidance for both Phase 3 requirements, which took effect in Nov. 2019, and for requirements relating to arbitration agreements, which became effective in Sept. 2019.

CMS notes that surveyors will begin using this guidance to identify non-compliance on Oct. 24 to allow time for surveyors and facilities to be trained on this new information. By that date, CMS will also complete updates to other survey documents, including the Critical Element (CE) Pathways, which are used for investigating potential care areas of concern.

This page includes a link to the advance copy of the revised Appendix PP itself, which highlights the new material in red.

Along with the updates to Appendix PP, CMS is updating guidance for state investigations of complaints and facility-reported incidents, designed to improve consistency in survey processes and communications, and revising the Psychosocial Outcome Severity Guide and F-tag 600 to enhance oversight of compliance related to ensuring a resident’s right to be free from abuse.

CMS has posted publicly available training for nursing home surveyors and providers in the Quality, Safety, and Education Portal (QSEP) that explains the updates and changes of the regulations and guidance. Search the Training Catalog for "Long Term Care Regulatory and Interpretive Guidance and Psychosocial Severity Guide Updates – June 2022." This portal is free to use, but registration is required.  

Because the CMS announcement broke just ahead of our deadline for this week’s newsletter, our team has not yet completed an analysis of the new guidance, but please know we are diving into that work and will provide additional information in the week ahead.

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