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 §483.15-Admission, Transfer, and Discharge guidance. Changes include the following citations:
-
F622-Transfer and Discharge Requirements. CMS provided clarification language for situations involving discharge from short-term rehabilitation, when Medicare coverage ends but the resident still needs long-term care, assisting residents to apply for Medicaid and explanation for denials, emergent transfers to acute care, and permitting return to nursing home.
-
F623-Notice Requirements Before Transfer/Discharge. CMS provided clarification on the components the transfer or discharge notice should contain and that a new notice would be required if a change in destination occurs.
-
F626-Permitting Residents to Return to Facility. CMS provided clarification that the requirement to permit residents to return after hospitalization or therapeutic leave applies to all residents regardless of payment source. CMS added language to investigative procedure to help surveyors investigate situations where a facility does not permit a resident return, as well as added a deficiency categorization example to show harm from a facility not permitting a resident to return after a hospitalization.
For all three citations, CMS added language that addresses against medical advice discharges. Detailed information can be found in the Appendix PP-State Operations Manual. The American Health Care Association (AHCA) has also provided a §483.15(c)(1) Planning Tool. AHCA has also developed a full summary that is found here. This information can only be accessed by WHCA members. Individuals will need to log in to the AHCA/NCAL website with their AHCA/NCAL usernames and passwords. For assistance obtaining usernames and passwords, please e-mail
help@ahca.orgwith your name and facility contact information.
If you have any questions, please email me or call me at (800) 562-6170, extension 105.
