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 has provided information on the updated guidance for F658-Professional Standards. The guidance now includes the following wording, “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 were added to the guidance at Professional Standards (F658). Guidance for citing noncompliance and examples were also included.”

Additional takeaways include but are not limited to the following:



• Mental Disorders are diagnosed by a practitioner, using evidence-based criteria and professional standards, such as the current version of the Diagnostic and Statistical Manual of Mental Disorders (DSM), and are supported by documentation in the resident’s medical record. 
• The guidance provides additional examples of insufficient documentation to support a mental health diagnosis and examples of insufficient documentation for a new mental health diagnosis. 
• When residents are admitted to the facility with a mental health diagnosis, supporting documentation should include, but is not limited to the following: 
• The PASARR evaluation and determination report from the State Mental Health Authority
• Facility attempts to obtain documentation regarding the mental health diagnosis from the previous provider(s)
• Validation of the resident’s mental health diagnosis by the practitioner in accordance with professional standards of practice, such as reviewing information available in the medical record, including information from the previous provider(s), discussions about the diagnosis and history with the resident or resident representative, conducting a comprehensive evaluation, the need for psychiatric or other consultations if necessary, and their determination of the resident’s diagnosis. 

For additional information AHCA’ F-Tag Action Tool-F658 Professional Standards 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.