Update to the Revised 2025 Survey Guidance

March 11, 2025
Regulatory

CMS has announced a delay in the nursing home survey changes.  The changes will now go into effect on April28th, 2025, giving providers a one-month reprieve.

Here is a quick review of the most important revisions in the guidance to Surveyors.

MDS Assessments and Corrections must compliantly and correctly reflect a resident’s status.  

  • Misreporting of 1 or 2 incidences is isolated.
  • Misreporting 3 or more times may be considered widespread.

 

Mental disorder diagnoses must be compliantly and correctly coded on the MDS with adherence to professional diagnostic standards as in the current version of the DSM (Diagnostic Statistical Manual of Mental Disorders) and supported by comprehensive, evidence-based documentation.  

 

Further, Medical Directors are to:

  • Provide oversight of all medical care delivered in the facility with a particular focus on new psychiatric diagnoses and psychotropic medication usage.  
  • Assure practitioners are delivering care within current professional standards.  
  • Be involved in resident care policies in relation to their physical, mental, and psychosocial well-being.  
  • Ensure facility care policy is adhered too.
  • Be actively involved in the facility assessment.
  • Be a part of the QAA (Quality Assessment and Assurance) committee, although they can assign a representative.  

 

The new key measure for QAA and QAPI is health equity and developing feedback systems to work toward improvement.

 

Other items of interest in the guidance include:

  • Third parties cannot be held personally liable for payment of resident care within Admission Agreements.
  • The PBJ Staffing Data Report will be used as another tool in determining if a facility has sufficient nursing coverage.
  • An Inappropriate Discharge has been further defined indicating there must be evidential support with documentation showing the reason(s) for discharge in alignment with recommendations in 483.15(d)(1)(i)(ii).