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CMS Nursing Home Survey Guidance Changes

In June, the Centers for Medicare and Medicaid Services (CMS) issued memorandum QSO 22-19-NH outlining changes to the Surveyor Interpretive Guidance (Appendix PP). Nursing homes will be surveyed using this new guidance beginning Oct. 24, 2022. The guidance changes reflect clarifications and technical corrections of Phase 2 guidance issued in 2017 and new guidance for Phase 3 requirements that went into effect on Nov. 28, 2019.

Members should visit the LeadingAge NY website for resources and tools compiled by LeadingAge NY and LeadingAge National that they should find helpful in updating policies and procedures. New resources developed by LeadingAge National include:

The page also contains links to training videos produced by CMS that explain the changes in specific regulatory areas. This should be helpful in familiarizing staff with the updated guidance.

One area of note is the guidance related to Abuse, where CMS characterizes the changes as significant. The guidance clarifies facility-reported incidents and provides examples of cases and what information should be reported. The guidance better articulates the requirement that a nursing home must report an allegation of abuse immediately, but no later than two hours after the allegation. As presented in the New York State Department of Health (DOH) Nursing Home Incident Reporting Manual, the reporting timeframe is unclear to providers.

Contact: Elliott Frost, efrost@leadingageny.org, 518-441-8761