Tuesday, October 1, 2019

Requirements of Participation – Phase 3: What’s the Latest Update?

Pam Truscott and Sara Rudow

In July, CMS issued a proposed rule that aims to ease some of the administrative and paperwork burdens of the Requirements of Participation (RoPs). The proposed rule includes changes to the current long-term care RoPs and survey process designed to reduce excessively burdensome and overly prescriptive regulations, while allowing centers to focus on providing high-quality care. AHCA has provided a detailed summary of the proposed rule here.

The proposed rule includes several changes AHCA has advocated for, such as reasonable restrictions on when facilities must send a copy of the transfer/discharge notice to the Long Term Care Ombudsman and requiring that providers receive a written notification for IIDR decisions, including the rationale for the independent reviewer’s recommendation and the written rationale for the final decision by CMS. 

CMS has proposed changes to elements of the Phase 3 requirements for the Quality Assurance and Performance Improvement (QAPI) program and the Compliance and Ethics program to make the requirements less prescriptive and more aligned with existing statute. It is important to know that until the proposed rule is finalized, facilities should prepare to implement all areas that are currently stated in the Phase 3 Requirements of Participation. Keep in mind that QAPI and Compliance and Ethics are keys to success for any organization.

Phase 3 requirements for culturally competent and trauma-informed care, infection preventionist, comprehensive training program, and call lights from the residents’ bedsides remain unchanged and will be fully in effect as of November 28, 2019. AHCA will continue to update members about any new information regarding the status of the proposed changes and Phase 3 implementation, including the release of CMS interpretive guidelines for these Phase 3 requirements.

To help centers navigate through the ROP Phase 3, AHCA has developed a number of resources which can be found on ahcancalED. You can find Phase 3 overview materials, including a video, summaries, and implementation checklists, as well as several resources related to behavioral health and trauma informed care, including a webinar on how to get started here. You can access toolkits and a webinar series on compliance and ethics here, and if you haven’t already signed up for AHCA’s IPCO course, now is the time! To see a complete listing of resources and tools available, visit ahcancalED.

If you have any questions, please send them to regulatory@ahca.org.

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