The Centers for Medicare & Medicaid Services (CMS) has issued CMS Memo QSO-25-07-NH (PDF) — Revised Long-Term Care (LTC) Surveyor Guidance: Significant revisions to enhance quality and oversight of the LTC survey process.
The memo announces revised guidance and associated training, which is available upon release of this memorandum for surveyors and providers.
Revised Survey Resources will be posted, and enforcement begins on Feb. 24, 2025.
The memo includes an advance copy of the Critical Element Pathways and an advanced copy of Appendix PP.
CMS has released the following revised guidance for nursing home surveyors:
- Admission, Transfer and Discharge: Admission Agreement: Clarified guidance prohibiting admission agreements from containing language requesting or requiring a third-party guarantee of payment. CMS is deleting Tags F622 – F626, and F660 – F661 and removing the terms “facility-initiated” and “resident-initiated.” The new citations are F627 for Inappropriate Transfers and Discharges and F628 for Transfer and Discharge Process.
- Chemical Restraints/Unnecessary Psychotropic Medication: The regulations and guidance for the unnecessary use of psychotropics (F758) have been incorporated into F605.
- Professional Standards and Medical Director: Instructions for investigating adherence to professional standards of practice when concerns arise regarding residents diagnosed with a condition without sufficient supporting documentation for which antipsychotic medications are an approved indication (F658).
- Accuracy/Coordination/Certification: Instructions for investigating Minimum Data Set (MDS) assessment accuracy and determining whether noncompliance exists when a concern related to insufficient documentation to support a medical condition is identified for a resident receiving an antipsychotic medication (F641).
The regulatory references and guidance under Coordination/Certification of Assessment (F642) are being relocated to Accuracy of Assessment (F641), and tag F642 has been deleted. - Comprehensive Assessment after Significant Change: Revisions were made to update the language to reflect the levels of assistance a resident receives for self-care and mobility activities to align with Section GG of the MDS (F637).
- Cardio-Pulmonary Resuscitation (CPR): Updates were made to CPR certification to align with current nationally accepted standards (F658).
- Pain Management: Revisions to the guidance for acute, chronic, and subacute pain were made to align with CDC definitions (F697).
- Physical Environment: Revisions were made to allow facilities that receive approval of construction from state or local authorities, or are newly certified after Nov. 28, 2016, with two single occupancy rooms with one bathroom, to meet the bedroom and bathroom facility requirements without undergoing major rehabilitation (42 CFR §483.90 Physical Environment – Life Safety Code tags).
- Infection Prevention and Control: Infection control guidance regarding Enhanced Barrier Precautions in Nursing Homes to Prevent Spread of Multidrug-resistant Organisms (MDROs) released in CMS Memo QSO-24-08-NH on March 20, 2024, was incorporated into Appendix PP along with new deficiency examples (F945).
- COVID-19 Immunization: Guidance related to requirements for facilities to educate residents or resident representatives and staff regarding the benefits and potential side effects associated with the COVID-19 vaccine and offer the vaccine released in CMS Memo QSO-21-19-NH on May 11, 2021, was incorporated into Appendix PP (887).
For more details and information, read CMS Memo QSO-25-07-NH (PDF).