LeadingAge National Releases New Requirements of Participation Resources for Nursing Homes

LeadingAge has been working to prepare tools and resources for nursing home members to use to comply with the new Centers for Medicare and Medicaid Services (CMS) Requirements of Participation (RoPs). LeadingAge National and state partners have contracted with Pathway Health, a consulting firm, to prepare the basic information members will need to understand the new regulations and update your policies and procedures.

The following toolkits were added last week to the LeadingAge National Nursing Home RoPs Tools and Resources page, which is being continually updated to assist members in preparing for the Oct. 24, 2022 compliance deadline:

• Infection Control
• Psychotropic Medication Use
• Drug Regimen Review

Also last week, CMS posted a revised advanced copy of Appendix PP as an attachment to memorandum QSO-22-19-NH. The advanced copy was revised to include new regulatory language that was finalized in the Fiscal Year (FY) 2023 Skilled Nursing Facility (SNF) Prospective Payment System (PPS) Final Rule (CMS 1765-F). The new regulatory language is related to food and nutrition services at §483.60(a)(2)(i)(E) on page 605 and physical environment at §483.90(a)(1)(iii) on page 794. The effective date of the new regulatory language finalized in the SNF PPS rule is Oct. 1, 2022.

Finally, CMS last week released updated Critical Element Pathways related to the new RoPs guidance. The Critical Element Pathways, the protocols that guide surveyors through investigation on surveys, are available in the Downloads section of QSO-22-19-NH and will go into effect on Oct. 24, 2022.

We encourage all members to take advantage of these new resources and tools to assist you with policies and procedures, education, and audits. If you have further questions, please feel free to reach out to Amy Nelson.

Contact: Amy Nelson, anelson@leadingageny.org, 518-867-8383 ext. 146