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CMS appears to be delaying surveying for Phase III requirements—More to come!

Doug Beardsley
By Doug Beardsley  |  November 8, 2019  |  SNF/NF providers

On October 30, 2019, the Association of Health Facility Survey Agencies (AHFSA) shared the following information with state survey agencies, including the Minnesota Department of Health (MDH):

Nursing Home Phase III Implementation Update
Phase III: The Centers for Medicare and Medicaid Services (CMS) will be releasing a memo hopefully later this week indicating that the interpretive guidelines will not be out before November 28th. Once the guidance is released there will need to be some time for implementation.  CMS will need time to update the software. Providers and state survey agencies will need time to conduct training. State survey agencies will not actively be surveying for the phase 3 requirements. However, if a situation arises that would refer to the new regulations in Phase 3,  it should be referred to the CMS regional office for review on a case-by-case basis. The example provided by CMS was an infection spreading throughout the facility that does not have an infection preventionist. This should be discussed with the regional office and the deficiencies would probably be cited under 880 for infection control.

Complaint Chapter 5 Update
The State Operation Manual (SOM) chapter 5 will not be updated prior to the interpretive guidelines for F609 being released. This will not be coming before November 28th.

At the time this article was written, CMS had still not released a Quality & Safety (QSO) memo pertaining to this topic. QSO memos can be viewed here, (sort by date, most recent first). 

The memo, once released, may provide more information regarding the CMS proposed changes to Phase III published earlier this year and other information regarding delays or implementation dates for Phase III requirements.

Doug Beardsley  |  Vice President of Member Services  |  |  952-851-2489

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