CMS Updates Phase 3 Requirements of Participation

In a proposed rule published July 16, 2019, the Centers for Medicare and Medicaid Services (CMS) proposed a number of changes to the nursing home Requirements of Participation (RoPs). One of the proposals was eliminating unnecessary details of the Quality Assurance and Performance Improvement (QAPI) mandate while maintaining overall intent and structure, removing the details that were too prescriptive. On Nov. 22, 2019, CMS released a memo stating that the RoPs for Phase 3 of the Final Rule would take effect Nov. 28, 2019 as previously written. CMS has not published interpretive guidance, bringing into question surveyors’ ability to inspect nursing homes in those areas. LeadingAge National has a summary of the updates and other requirements here.

For questions regarding state inspections and survey preparation, please contact Mary Wassel, Director of LeadingAge NY ProCare, at mwassel@leadingageny.org. For questions regarding quality improvement, please contact Susan Chenail, Senior Quality Improvement Analyst, at schenail@leadingageny.org.

Contact: Susan Chenail, schenail@leadingageny.org, 518-867-8383 ext. 116