On Monday, November 18th, CMS issued a memo noting its plans to implement revisions covering a range of topics to the long-term care survey guidelines. This new guidance will be effective February24, 2025. The goal is to consolidate the process and prevent overlapping citations. Training is offered for Providers and Surveyors, through the Quality, Safety, and Education Portal (QSEP).
MDS accuracy is a critical item in these revisions. The guidelines indicate Surveyors are to review coding for accuracy, and they are to refer known patterns of inaccurate coding and potential falsification to the Office of the Inspector General for further possible action.
Changes are being made in relation to admission agreements. A facility may not incorporate language into their agreements regarding a guarantee of payment from a third party. Numerous F-tags related to the transfer and discharge process are to be removed and replaced by two new citations for non-compliance with regulatory requirements and resident rights.
Other areas of revision include infection Control with the inclusion of the enhanced barrier precautions guidance. The requirement for educating residents and staff about COVID-19 immunization will also be incorporated. The guidance for psychotropic medications and chemical restraints has been changed and these items placed into tag F605versus F758. CMS made this change to curtail the unnecessary use of these types of medications for staff convenience and to safeguard a resident’s right to accept or refuse these medications. In relation to this, it is also noted prescriptions for antipsychotic medications need to have supportive documentation. CMS has also forwarded the guidelines related to the Facility Medical Director’s responsibilities, including ensuring other physicians and non-physician practitioners are following polices for diagnosing and medication prescription.
For Quality Assurance and Performance Improvement (QAPI) programs, facilities are to include health equity data related to medical errors, adverse events and resident outcomes and establish goals for improvement based on the results. Surveyors will be instructed to review data collection and improvement efforts.
Updates were also made to align with current guidance related to the ComprehensiveAssessment after Significant Change (Section GG), CPR certification, and pain management.
To review CMS’ Memo regarding the revised survey guidance, go to the following link - Revised Long-Term Care (LTC) Surveyor Guidance: Significant revisions to enhance quality and oversight of the LTC survey process | CMS.
This memo includes an advanced copy of Appendix PP - Guidance to Surveyors for Long Term Care Facilities and the Critical Element Pathways.