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CMS: Phase 3 RoPs Effective 11/28/19 – Expect Interpretive Guidance Q2 2020

The Centers for Medicare and Medicaid Services issued a new QSO Memo on November 22, 2019, “Updates and Initiatives to Ensure Quality and Safety in Nursing Homes.” The Memo states:

  • Phase 3 of the Requirements of Participation are still effective on November 28, 2019. Providers are expected to be in compliance with all regulations.
  • Updated Interpretive Guidance for Phase 3 Ftags is expected in Q2 2020. Surveyors are expected to survey utilizing the existing IG. The QSO memo reads: “While the Phase 3 requirements will be effective November 28, 2019, and facilities are required to comply with these and all requirements, our ability to survey for compliance with these requirements will be limited until the Interpretive Guidance is released.”
  • The guidance expected in Q2 2020 will also include changes to the LTCSP.

CMSCG will be posting more details on the full memo – which includes arbitration and infection control topics – shortly, but in the meantime, it can be viewed here.

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