|
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. These changes are effective starting February 24, 2025.
Effective February 24, 2025, CMS is deleting Tags F622 – F626, and F660 – F661 and removing the terms “facility-initiated” and “resident-initiated.” The guidance from the deleted tags has been reorganized, with revisions added to clarify when a transfer or discharge is noncompliant. The new regulatory requirements are found under F627 for Inappropriate Transfers and Discharges and F628 for Transfer and Discharge Process.
Additional takeaways include the following:
- F620- Admission Agreements: New guidance added clarifying the prohibition of language in the admission agreements that specifically request or require a 3rd party to guarantee payment to a facility personally. This includes examples of admission agreement language that would not be compliant.
- CMS removed the terms “facility-initiated” and “resident-initiated.” According to CMS, this change was to clarify that facilities should ensure a safe discharge, regardless of who initiates the discharge.
- During the off-site preparation for surveys, surveyors are directed to contact the local Ombudsman to determine if there have been recent complaints regarding improper discharges.
For more information, please find Survey Tips- Transfer and Discharge (Part 1 and Part 2) on the AHCA Survey Regulatory page. AHCA’s Transfer and Discharge Action Tool can also assist your facility to understand the changes, documentation requirements for discharges, and a list of action items to ensure your facilities 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 provides some tips/action items to be compliant ahead of the effective date. Available free to AHCA/NCAL members and $65 non-members. 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.
| 
