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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 guidance of §483.12 Freedom from Abuse, Neglect, and Exploitation and updated the Psychosocial Outcome Severity Guide. Changes include the following:
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F600- Abuse/Neglect. CMS removed language regarding sexual abuse and included additional guidance related to neglect.
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F604- Physical Restraints. CMS provided clarification for when bed rails meet the definition of a physical restraint.
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F607- Abuse Policies. CMS added guidance for coordination with QAPI and provisions from the former F608.
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F608- Reporting of Suspected Crimes. CMS deleted this guidance and added it to F-tags F607 and F609.
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F609- Reporting Alleged Violations. CMS revised definitions and guidance related to the timing of reports, added language related to what facilities must report, and added provisions from the former F608.
Technical changes were made to the following F-tags:
- F602-Free from Misappropriation/Exploitation
- F603-Free from Involuntary Seclusion
- F605-Right to be Free from Chemical Restraints
- F606-Not Employee Staff with Adverse Actions
CMS also updated the Psychosocial Outcome Severity Guide. This guide assists surveyors in determining the severity of the psychosocial outcome resulting from noncompliance and to assist surveyors in applying the reasonable person concept.
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.
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