The Centers for Medicare & Medicaid Services (CMS) released revised interpretive guidance in a June 30, 2017, survey and certification memo regarding the Phase 2 implementation of the revised Medicare and Medicaid requirements for participation for long-term care (LTC) facilities. Phase 2 is set to take effect November 28, 2017, and will include revised F-Tags and interpretive guidance for existing requirements and the new Phase 2 requirements.
Alongside Phase 2, CMS will implement a new computer-based LTC survey process effective November 28, 2017. This new survey process will be nationwide and blends elements of the traditional survey and Quality Indicator Survey processes.
CMS stated in the memo it will delay enforcement of penalties, denial of payment and termination of provider agreements for one year for specific Phase 2 requirements, opting instead to educate providers regarding these new requirements by having facilities provide a directed plan of correction and additional in-service training for staff. However, the one-year delay doesn’t change the November 28, 2017, requirement implementation date.
This resource list for providers can be downloaded here:
- List of revised F-Tags (effective November 28, 2017)
- F-Tag crosswalk
- Advance appendix PP including Phase 2 (effective November 28, 2017)
- New LTC survey process slide deck and speaker notes
CMS will begin training to help state agencies, providers and the public understand the new requirements with a Medicare Learning Network call on July 25, 2017, from 1:30 to 3 p.m. Eastern time. Providers can register for the event here.
Read the full survey and certification memo here. Contact your BKD advisor with questions or for more information.