Requirements of Participation (RoPs) Interpretive Guidelines for nursing facilities released

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On June 30, CMS issued Survey and Certification memo 17-36-NH, releasing the revision to the State Operations Manual (SOM) Appendix PP for Phase 2 along with the F-tag revisions. The survey protocols and interpretive guidelines serve to clarify the intent of the regulations.

A couple of key aspects of the memo include:

  1. Enforcement – CMS will provide a one-year restriction of enforcement remedies for specific Phase 2 requirements, to be shared at a later date. This means that CMS will not utilize civil money penalties, denial of payment, and/or termination in these situations, focusing on education on standards.
  2. Five Star Rating – Due to the differing standards of the new survey process and revised regulations, CMS will be “holding constant” for one year the Nursing Home Compare health inspection rating for any surveys conducted after November 28, 2017. CMS intends to “flag” facilities will serious quality issues to ensure public transparency. CMS will provide more information at a later date.
  3. Training – A number of training opportunities will be available in the future. Dates and links are noted in the S&C memo.

CMS has created a resources webpage for providers, and the surveyor training website can be found here.