In response to released guidance for Requirements of Participation (RoP) Phase 3 and updates for Phase 2, the American Health Care Association (AHCA) is providing focused information to help skilled nursing facilities remain in compliance and avoid any failed practice. We give special thanks to the AHCA Survey and Regulatory staff for compiling and distributing this information. Elena Madrid, WHCA's Executive Vice President for Regulatory Affairs, co-chairs the AHCA Survey and Regulatory Committee and is a member of AHCA's Quality Cabinet.


The Centers for Medicare and Medicaid Services (CMS) made changes to the §483.40-Behavioral Health Services. Changes include the following: 

  • F740-Behavioral Health Services. CMS removed reference to Appendix P and added reference to Psychosocial Outcome Severity Guide and language related to mental health and substance use disorders throughout the guidance. 
  • F741-Sufficient Staff, Competent Staff-Behavioral Health Needs. CMS removed reference to Appendix P and added reference to Psychosocial Outcome Severity Guide and added language related to history of trauma and/or post-traumatic stress disorder and language related to mental health and substance use disorders throughout guidance. 
  • F742, F743, and F744 had minor technical changes that included removal of the reference to Appendix P and addition of reference to the Psychosocial Outcome Severity Guide. 


AHCA members may also refer to existing member resources: 


Detailed information can be found in the Appendix PP-State Operations Manual. AHCA has also provided an expanded and full summary. If you have any questions, please email me or call me at (800) 562-6170, extension 105.