The Centers for Medicare & Medicaid Services (CMS) has delayed nursing home survey changes for another month, with implementation now to begin April 28 rather than March 24. Associations and providers alike are glad they’re being given more time to prepare, educate and test procedures.

CMS said the delay “allows ample time” for both surveyors and providers to be trained on the new information. LeadingAge had asked the agency fewer than 10 days ago to pause survey changes, with the regulatory freeze and ongoing pause in external communications from the Department of Health & Human Services (HHS). Such pauses impair nursing homes’ ability to interpret and implement the new survey changes, the association said.

“We appreciate CMS recognizing the need for this delay and look forward to assisting our nonprofit, mission-driven members in preparing for the new effective date,” said Jodi Eyigor, senior director of nursing home quality and policy for LeadingAge. “Additionally, we will continue advocating for the resumption of communications to ensure CMS provides the necessary clarification for nursing homes before implementing this guidance.”

The survey updates, initially included in a 900-page document on Nov. 19, detail new guidance on a variety of areas including admission agreements and medication management, as well as infection control and health equity considerations.

Two key areas operators have focused on include tags related to reduction of unnecessary psychotropic medications and updates to admission, transfer and discharge processes, operators said in November.

Surveyors will be using the updated State Operations Manual, Appendix PP Guidance on and after April 28.

Survey changes and the new administration

Michelle Stuercke, chief clinical officer at Transitional Care Management, said the survey changes are already rules as opposed to something proposed or something that still needs public comment. And so, the freeze on regulations and communications doesn’t really play into the decision to delay the survey changes, from her perspective. The delay is more to ensure the new administration and providers understand the changes and have their systems in place.

Associations including the American Health Care Association and National Center for Assisted Living (AHCA/NCAL) expressed gratitude that the agency pushed back implementation of the surveyor guidance for another month.

“We will continue to advocate to CMS that the survey system support quality improvement, and we look forward to an ongoing dialogue with CMS on improving guidance so providers can continue to deliver high-quality care to the residents we serve,” said Holly Harmon, senior vice president of quality, regulatory and clinical services at AHCA/NCAL.

The delay isn’t completely surprising, and it’s important for providers to still be prepared for the changes on April 28, said Amy Stewart, chief nursing officer for the American Association of Post-Acute Care Nursing (AAPACN).

“I would recommend using this extension to ensure policies are updated and that leaders have sound processes in place,” Stewart told Skilled Nursing News. “This time can also be used to provide more detailed education on the changes.”

That’s exactly what nursing home operators like Brickyard Healthcare are doing, using the time to continue offering education regionally and generally to ensure leaders understand the new regulatory requirements and can focus on efforts to get all bedside caregivers and interdisciplinary team members trained, said Lisa Chubb, chief clinical officer for Brickyard. Indiana-based Brickyard operates skilled nursing centers across the Hoosier State.

If facilities will already have education and policies or processes updated, operators can audit for compliance in this time, Stewart said.

Overall, the delay is a positive for the industry, said Stuercke.

“Any time you have some additional time to prepare, it’s always better, right? But, it’s also important for organizations to take this gift and act upon it,” said Stuercke. “I think it’s really important that we take this gift and act upon it and really deep dive into our systems and make sure that they’re in place.”

It’s easy to assume it will be delayed again or that it’s not going to happen, but providers would do well not to fall into this way of thinking, Stuercke added. Facilities should take the extra time to make sure they have all the processes and education in place prior to implementation.

Areas of focus

Stewart suggested using the time to look over admission, transfer and discharge processes. Appendix PP covers several changes that impact these policies and processes, she said. And, updated changes under F620 for admission policy indicate that if an individual doesn’t have legal access to a resident’s funds, the facility can’t request or require the individual to pay the facility.

“Facility leaders should review their current admissions policy to ensure that the current language meets the future changes. If not, the policy will need to be updated and staff educated on the change,” said Stewart. Once that’s done, audits for compliance can be done.

When it comes to inappropriate transfer or discharge, surveyors need to review the medical record documentation to determine if staff documented the reason for discharge, Stewart said.

“If the facility indicated they could no longer meet the resident’s care needs, surveyors will review the documentation to determine if there is evidence to support this claim. The same holds true for discharges based on improvements in the resident’s health status,” said Stewart.

The upcoming changes were a hot topic at Skilled Nursing News’ recent CLINICAL Executive Conference in Florida. There, leaders including Stuercke and Chubb spoke about a number of the updates and what providers need to do in order to remain compliant, such as ensuring that patients can understand discharge communications in terms of the format and language being used.

CMS has made guidance training publicly available for nursing home surveyors and providers through the Quality, Safety, and Education Portal (QSEP), the agency said in the memo. Training for nurse staffing and Payroll Based Journal (PBJ) has been added to existing training in QSEP, the agency said.

States will receive a revised Quality Improvement Evaluation System (QIES) technical support office memo with information on updating survey software and accessing software training prior to April 28, according to the memo.