CMS’ Director, Division of Nursing Homes – Evan Shulman provided some clarity around the Phase 3 Requirements of Participation eff date of 11/28/19 in October of this year at the Leading Age National Conference. He shared that while Phase 3 of the RoP remains effective as of 11/28/19, there is not a date yet for the release of guidance and implementation for Surveyors. CMS is determining how these Phase 3 requirements relate to other initiatives in place such as QAPI and the reduction of burden in combination with PDPM.
Priorities:
Stressed was the importance of moving forward with having an Infection Preventionists identified on staff and to have them take CMS’ training. The #1 citation remains infection control (hand washing – “Alcohol based hand rubs are the preferred method”)
Phase 3 Requirements of Participation include:
Compliance and Ethics Program
Physical Environment
Dietary
QAPI
Person Centered Care Planning/ Trauma Informed Care
Infection Preventionist
Training Requirements for Staff Competencies
Let's Get to the Point:
While there are calls out to CMS for delays on the Enforcement of all Phase 3 requirements, CMS has not provided clarification on how compliance will be assessed, and we stand at 11/28/19 with Phase 3 facing us. Hoping this checklist helps provide clarity.