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 §483.30-Physician Services and §483.35 Nursing Services. Changes include the following citations:

§483.30-Physician Services
  • F712-Physician Visits-Frequency/Timeliness/Alternate NPPs. This citation includes an update to the authority for non-physician practitioners to perform visits, sign orders, and sign Medicare part A certifications and re-certifications when permitted by the state. CMS also updated the existing example of level 2 non-compliance. 

§483.35 Nursing Services
  • F725 – Sufficient Staff and F727 – Registered Nurse. These new citations provide guidance on procedures, probes, and deficiency categorization.
  • F729 – Registered Verification. New procedures and probes were added.
  • F732 – Nurse Staffing Information. Under this citation, CMS clarified the use of Payroll Based Journal (PBJ) data by surveyors to identify concerns with staffing. 

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