SNF Compliance Tips for Care Plan, Pharmacy, Smoking Requirements

Skilled nursing providers across the country continue to work hard as Nov. 28 approaches. That’s when the second phase of the new SNF Medicare and Medicaid requirements of participation take effect.

The so-called “mega rule” is being implemented in three phases, and this second phase brings a host of new requirements. Here are a few areas to double-check and some tips for readiness, shared Sunday at the annual LeadingAge conference in New Orleans by Lisa Thomson, chief marketing and strategy officer at consulting and education firm Pathway Health:

Baseline care plan


Skilled nursing facilities now will be required to create a baseline care plan, including information such as initial resident goals, physician orders, medication summary and dietary instructions. The plan must be shared with the resident and/or the resident’s representative within 48 hours of admission, Thomson emphasized.

This holds true even for a resident admitted, say, late in the day on Friday.

“The clarification we’ve been hearing from everyone is … 48 hours is 48 hours,” she said.


So, SNFs will want to educate their staff and provide tools as needed to complete the baseline care plan reliably within that timeframe. For instance, social workers might not work on weekends, so nurses will have to be able to complete the care plan without them on those days.

Educating the whole interdisciplinary team so that members can articulate how they contribute to the baseline care plan process is also critical—surveyors will be asking them about this, Thomson said.

And this tip goes beyond the baseline care plan to practically every aspect of the new requirements of participation.

“Our staff has to understand their role in this process,” she said.

Pharmacy services

Another overarching tip is to ensure that staff are aware of how CMS is defining key terms in the new requirements of participation. One example is the term “irregularities” under the pharmacy regulations.

These pharmacy regulations call for a drug regimen review to take place at least monthly, with one goal being to catch “irregularities.” The definition of irregularities concerns potentially inappropriate medication use, such as an excessive dose or duration.

Physical environment

Policies regarding smoking now are set to kick in—which are presenting a particular challenge to some providers.

These requirements do not just concern smoking cigarettes but also vaping of electronic cigarettes, as well as smoking cessation programs, Thomson stressed.

“Our policy cannot just be, we don’t smoke in the building, [residents] have to go … to a designated smoking area,” she said.

Surveyors are likely to carefully consider a facility’s smoking policies, considering that lives have been lost in smoking-related incidents, she cautioned.

Just one day after Thomson made her comments at the LeadingAge conference, the St. Louis Post-Dispatch reported on a lawsuit against a local nursing home where a resident died after catching fire while smoking.

Written by Tim Mullaney

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