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 §483.25-Quality of Care guidance. Changes include the following: 

• F686-Pressure Ulcers. CMS updated guidance to reflect frequency of completion of risk assessments, clarification for determining if skin damage is a PI/PU, as well as requirements to prevent infection. 
• F687-Foot Care. CMS added new language to address proper infection prevention and control practices for foot care equipment. 
• F689-Accidents/Supervision. CMS added components related to electronic cigarettes or e-cigarettes and safety for residents with substance use disorder. 
• F690-Bowel/Bladder Incontinence, Catheter, UTI. CMS clarified that regulation is specific to bowel incontinence not bowel management. 
• F694-Parentaeral/IV Fluids. CMS added components on assessing intravenous (IV) therapy sites, assessing the continued need for an IV, and components related to professional standards of practice for cleaning. 
• F695-Respiratory/Tracheostomy Care and Suctioning. CMS provided clarification that the guidance related to mechanical ventilation only applies to facilities offering this type of care. 
• F697-Pain Management. CMS added language regarding use of opioids within the current opioid crisis, recommended resources for use of opioids, provided guidance on assessment of resident with history of addiction, as well as guidance on opioid side effects and overdose prevention. 
• F699-Trauma-Informed Care. CMS provided definitions associated with culturally competent and trauma-informed care, key elements of noncompliance, and investigative summary and examples of non-compliance.
• F700-Bedrails CMS clarified the guidance to include the “use” of bedrails in addition to installation, added links to alternatives, and clarified removal requirements.  

AHCA members may also refer to existing member resources: 

• Trauma Informed Care
• Behavioral Health and Trauma Informed Care
• Trauma Informed Care: How do I Start?

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.