CMS Releases Revised Surveyor Guidance and Updates to Appendix P

The Centers for Medicare and Medicaid Services (CMS) recently posted advance copies of revised surveyor guidance and updates to Appendix P of the State Operations Manual. The changes to Appendix P are to be implemented no later than December 1st and include Survey Protocols for LTC Facilities revised for the traditional survey process.  Tasks 1 - 5 C reflect changes for the following:

  • Minimum Data Set (MDS) 3.0;
  • New Quality Measures (QM) Reports;
  • Sampling and reviewing residents receiving psychopharmacological medications, specifically antipsychotic medications.

Also included in the release are updates to several forms (Survey Forms 672, 802, 802S, and 802P).  According to CMS, there may be a transition period of several months in each State as surveyors are trained and the new protocols and forms are fully implemented by December 1, 2012.  CMS advises that nursing facilities should begin to transition their MDS software applications that automatically produce forms 672, 802 and/or, 802P and be prepared to provide survey teams with either the old or new forms, depending on the States implementation of these new protocols and forms.  (We have not been advised when Virginia surveyors will be trained on the new protocols.)  Revisions to Chapter 9 of the SOM include various exhibits including survey forms that have been revised to accommodate changes for MDS 3.0 and the new QM Reports.

The advance copies of the following surveyor guidance updates, to be implemented no later than November 30, 2012, include:

  • F 155 - Advance Directives which contains changes to surveyor guidance to provide clarification to nursing home surveyors when determining compliance with the regulatory requirements for Advance Directives. The regulatory language remains unchanged.  
  • F 322 - Feeding Tubes which includes revisions to interpretive guidelines to provide clarification to nursing home surveyors when determining compliance with requirements for feeding tubes. The regulatory language will remain unchanged.  CMS deleted F tag 321 which contained language about not using feeding tubes unless unavoidable, and incorporated the guidance into F tag 322.  
  • F 309 – End of Life Care. The changes to F 309 provide clarification to surveyors when determining compliance for End of Life regulatory requirements although the language remains unchanged.  

There was also an S&C memo posted indicating that the training material Hand In Hand: A Training Series for Nursing Homes to be sent to all facilities no later than December 2012.  

The Affordable Care Act requires CMS to ensure that nurse aides receive regular training on caring for residents with dementia and on preventing abuse.  CMS created this training program to address the requirement for annual nurse aide training on these important topics.  The Hand in Hand training materials consist of an orientation guide and six one-hour video-based modules, each of which has a DVD and an accompanying instructor guide. Though Hand in Hand is targeted to nurse aides, CMS believes the training may be valuable to all nursing home caregivers, administrative staff and surveyors.