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In November 2024, the Centers for Medicare and Medicaid Services (CMS) released Revised Long-Term Care (LTC) Surveyor Guidance. The memo included significant changes to guidance in Appendix PP. The memo was updated January 16, 2025, to include additional changes to the guidance. The changes will be effective, and surveyors will begin surveying based on the revised guidance, on March 24, 2025. Note: The effective date was delayed from the original memo.
CMS is incorporating the revisions to the guidance for acute, chronic, and subacute pain that were made to align with CDC definitions. CMS also clarifies that clinicians may consider prescribing immediate-release opioids instead of extended-release or long-acting options and emphasizes the need for individualized opioid treatment plans for residents. Additionally, CMS has updated and expanded resource links related to opioid use.
Additional takeaways include the following:
Facilities need to familiarize staff, including prescribers, with the updated definitions for pain in the revised guidance. These definitions include the following:
- “Acute Pain” refers to pain that is usually sudden in onset and time-limited with a duration of less than 1 month and often is caused by injury, trauma, or medical treatments such as surgery.
- “Chronic Pain” refers to pain that typically lasts greater than 3 months and can be the result of an underlying medical disease or condition, injury, medical treatment, inflammation, or unknown cause.
- “Subacute Pain” refers to pain that has been present for 1–3 months.
- These definitions play a key role in revised CMS guidance and the need for facilities to ensure that residents have an individualized and resident centered plan of care, especially related to pain management. CMS goes on to state the following:
“Prescribing practitioners may find that opioid medications are the most appropriate treatment for acute pain, subacute pain, and chronic pain in some residents. Opioid treatment for pain needs to be appropriately assessed and individualized for each resident. However, because of increasing opioid addiction, abuse, and overdoses, prescribers should use caution when prescribing opioids, and consider using alternative pain management approaches, when appropriate. When opioids are used, the lowest possible effective dosage should be prescribed for the shortest amount of time possible after considering all medical needs and the resident should be monitored for effectiveness and any adverse effects. When starting opioid therapy for acute, subacute, or chronic pain, clinicians may consider prescribing immediate-release opioids instead of extended-release and long-acting.”
For additional information AHCA’ F-Tag Action Tool-F697 Pain Management contains actions items and a check list which can assist your facilty with regulatory compliance.
AHCA has also developed an on-demand webinar that walks learners through each of the changes to guidance, the updates to the Critical Element Pathways (CEP), and some tips/action items necessary in order to be compliant ahead of the effective date. As a result of the updated CMS memo, additions and extending the effective date for the Appendix PP changes have been made to AHCA’s webinar, AHCA Education: Preparing for Upcoming CMS Guidance Changes: Key Updates and Action Items for Compliance. This webinar is on demand and available free to AHCA/NCAL members and $65 non-members. Remember if you are a member of Washington Health Care Association, you are also a member of AHCA and take advantage of this free resource. Please send questions to regulatory@ahca.org, and email educate@ahca.org if you need assistance with registering.
Thank you to AHCA for the development of the information contained within this communication and the associated tools. If you have questions, please contact Elena Madrid, Executive Vice President of Education and Regulatory Affairs.
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