Friday, December 20, 2019

Phase 3 Interpretive Guidance – Delayed

Pam Truscott

Phase 3 of the Requirements of Participation (RoP) went into effect on November 28, 2019. However, as the Centers for Medicare & Medicaid Services (CMS) announced in a memo (QSO-20-03-NH) released on November 22, 2019, CMS will not be releasing the interpretive guidance (IG) for Phase 3 until the second quarter of 2020.  Centers are expected to comply with all requirements. However, CMS stated that surveyors will have limited ability to survey for compliance with the Phase 3 requirements until the IGs are released.

Phase 3 regulations include the implementation of the following key areas:
  • Infection Preventionist
  • Compliance and Ethics Program  
  • Quality Assurance and Performance Improvement (QAPI) Program
  • Trauma-informed Care
  • Beside Call System
  • Comprehensive Training Program
Although the IGs are an important tool to help you implement these requirements, there are many steps centers can take now using tools and resources AHCA has developed to navigate Phase 3.  We encourage you to visit the ahcancalED platform located at https://educate.ahcancal.org/. Examples of resources include: Phase 3 overview materials, behavioral health and trauma informed care, infection preventionist role & competencies including the Infection Prevention and Control Officer (IPCO) training, Compliance and ethics program, as well as a plethora of general resources to support the implementation and compliance of Phase 3.


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