Survey Preparedness

​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​Skilled nursing centers and nursing facilities are required to follow extensive rules in the Requirements of Participation (ROP) to receive payment under the CMS Medicare or Medicaid programs. These requirements are contained in the Federal Regulations for Nursing Facilities, which also state each center must comply with all applicable Federal, State, and local laws, regulations, and codes with accepted professional standards. The AHCA regulatory team provides members guidance and resources to help understand the survey process and implement the requirements.  

 Focus F-Tags: Guidance for ROP Phase 2 and 3

​​On June 29, ​2022, CMS released new guidance for Requirements of Participation Phase 3. Each week through October, AHCA will highlight a particular F-tag(s) to help providers better understand the Phase 2 updates and Phase 3 new guidance. Providers can find Focus F-Tag weekly summaries on this page.

Please refer to Appendix PP Gu​​idance to Surveyor for Long Term Care Facilities​​​ for the most up to date regulations and guidance.​​ ​

 F-Tag Action Briefs & Much More on ROP

Additional resources and tools to help you navigate the ROP are available on ahcancalED, including F-Tag Action Briefs, which complement the summ​a​ries above and highlight implementation strategies and tips​.  



Trauma Informed Care Proficiency is Key to Survey Success Informed Care Proficiency is Key to Survey Success11/28/2022 5:00:00 AM<div><span style="font-size:14.6667px;">​​​Surveyors began applying new Phase 3 Requirements of Participation (ROP) guidance covering Trauma Informed Care (TIC) in October. TIC is an approach to care that requires specific staff competency and a system of care delivery that provides the necessary support to care for residents who may suffer from trauma. </span></div><div><span style="font-size:14.6667px;"><br></span></div><div><span style="font-size:14.6667px;">TIC also is a regulatory requirement for all skilled nursing facilities. Nine CMS F-Tags (F699, F656, F659, F740, F741, F742, F743, F745, F949) cover various aspects of TIC (including the psychosocial outcome severity guide) making compliance with this critical form of care vital to nursing facility survey success and quality care. </span></div><div><span style="font-size:14.6667px;"><br></span></div><div><span style="font-size:14.6667px;">The <a href="" data-feathr-click-track="true">TIC Training</a> contains simple foundational steps and practical recommendations for implementing a TIC program that can help improve resident outcomes and regulatory compliance. Individuals will learn how to screen and assess for trauma and incorporate TIC into the discharge process. There also is a focus on building awareness of TIC among staff to help them deliver appropriate care and deliver meaningful activities and other services from a TIC perspective.  </span></div><div><span style="font-size:14.6667px;"><br></span></div><div><span style="font-size:14.6667px;">This nine-module online course was developed through a joint collaboration between AHCA/NCAL and the American Association of Post-Acute Care Nursing (AAPACN). The training is designed to educate long term care providers and nurses about how to implement TIC in their facilities with staff who are appropriately trained and competent to care for residents who are at risk for re-traumatization. </span></div><div><span style="font-size:14.6667px;"><br></span></div><div><span style="font-size:14.6667px;">TIC is an important aspect of care given that 62 percent of adults have had at least one traumatic event and 25 percent have had three or more traumatic events.    </span></div><div><span style="font-size:14.6667px;"><br></span></div><div><span style="font-size:14.6667px;">The cost of the program is $350 for AHCA/NCAL members and $650 for non-members. The program is approved for 5.75 NAB CEs for administrators and 5.10 AANC continuing education hours for nurses.</span></div><div><span style="font-size:14.6667px;"><br></span></div><div><span style="font-size:14.6667px;">Members will need to login to <em>ahcancalED</em> with their AHCA/NCAL usernames and passwords to <a href="" data-feathr-click-track="true" target="_blank">register for the course</a>.  For assistance obtaining usernames and passwords, members should e-mail <a href="" data-feathr-click-track="true" target="_blank"></a> with their name and facility contact information.  </span></div><div><br></div>Surveyors began applying new Phase 3 Requirements of Participation guidance covering Trauma Informed Care in October.
An Efficient Path for Demonstrating SNF Staff Competencies to Surveyors Efficient Path for Demonstrating SNF Staff Competencies to Surveyors11/21/2022 5:00:00 AM<p></p><div>Surveyors are in full swing using the Phase 3 CMS Requirements of Participation (ROP) guidance to identify skilled nursing facility (SNF) noncompliance. SNFs must develop, implement and maintain effective training programs for all staff based on each facility’s resident population and facility assessment which likely will change over time.   </div><div><br>​<span style="font-size:11pt;">AHCA/NCAL offers two online programs in conjunction with Healthcare Academy®. Both programs incorporate a digital competency platform to allow for docum​entation of live skills demonstration. The digital checklists included in these programs have been designed by industry experts using evidence-based practices to help organizations develop competent and confident staff.</span></div><div><br></div><div><em><a href="" data-feathr-click-track="true" target="_blank">AHCA’s Requirements of Participation eCompetencies</a></em>® is designed specifically to help skilled nursing facilities comply with F-Tag 726 under CMS’ Requirements of Participation (ROP).  The program offers an extensive library of evidence-based skills checklists that allow evaluators to assess and document staff skills in real time. Videos are included to aid in skill progression and remediation. AHCA’s ROP eCompetencies® is a comprehensive competency tool that is inter-disciplinary and relevant to all facility staff.  </div><div><br></div><div><em><a href="" data-feathr-click-track="true" target="_blank">AHCA/NCAL’s Infection Control Certificate Program</a></em> features five eLearning modules and five eCompetencies® focused on infection control:  <br></div><div><br></div><div style="text-decoration:underline;"><em>eLearning</em></div><div>eLearning modules designed to provide staff with basic knowledge in the following:</div><div><br></div><div>a.<span style="white-space:pre;"> </span>Infection Prevention and Control for All Staff   <br></div><div>b.<span style="white-space:pre;"> </span>Coronavirus Disease (COVID-19)                    </div><div>c.<span style="white-space:pre;"> </span>Personal Protective Equipment (PPE)  </div><div>d.<span style="white-space:pre;"> </span>Hand Hygiene  </div><div>e.<span style="white-space:pre;"> </span>COVID-19: PPE Guidance for Use         </div><div><br></div><div style="text-decoration:underline;"><em>Competencies</em></div><div>Complete evidence-based digital checklists allow evaluators to confirm step-by-step knowledge and skill staff competency for:  </div><div><br></div><blockquote style="margin:0px 0px 0px 40px;border:none;padding:0px;"><div>a.<span style="white-space:pre;"> </span>Personal Protective Equipment (PPE): Applying and Removing</div><div>b.<span style="white-space:pre;"> </span>Handwashing</div><div>c.<span style="white-space:pre;"> </span>Surgical Face Mask: Application and Removal</div><div>d.<span style="white-space:pre;"> </span>N95 Respirator Application and User Seal Check</div><div>e.<span style="white-space:pre;"> </span>Cleaning and Disinfecting Environmental Surfaces</div></blockquote><div><br></div><div>Providers that participate will have access to a marketing tool kit to support their facilities’ need to publicize their commitment to staff education about infection control. </div><div><br></div><div>Each program is designed to consistently train and test competency of staff members, and to electronically document staff performance as their learned skills are being evaluated. Reporting functions make it easy to track skill competency by staff member and share that information with state surveyors. The programs can be used on a laptop, iPad, and mobile device.    </div><div><br></div><div>Both programs are available for purchase by facilities (not individuals) at the following cost for each:  </div><div><ul><li>AHCA/NCAL Member Pricing for facilities with 0-200 Staff Members per facility: <strong>$1,500.00</strong></li><li>AHCA/NCAL Member Pricing for facilities with 201+ Staff Members per facility: <strong>$</strong><strong>2,000.00</strong></li><li>AHCA/NCAL Non-Member Pricing for facilities with 0-200 Staff Members per facility: <strong>$2,000.00</strong></li><li>AHCA/NCAL Non-Member Pricing for facilities with 201+ Staff Members per facility: <strong>$</strong><strong>2,500.00</strong></li></ul></div><div>Prices include unlimited facility use for one year from date of purchase. Prices may vary for existing Healthcare Academy clients, so members who are clients should check pricing with Healthcare Academy prior to purchase.  </div><div><br></div><div>Call <strong>(866) 323 4169</strong> or email <a href="" data-feathr-click-track="true" target="_blank"></a> if you have questions about either program. <br></div><div><br></div>Surveyors are in full swing using the Phase 3 CMS Requirements of Participation guidance to identify skilled nursing facility noncompliance.
Listen to HealthCap’s Free Podcast Highlighting ROP3 Changes’s-Free-Podcast-Highlighting-ROP3-Changes.aspxListen to HealthCap’s Free Podcast Highlighting ROP3 Changes10/31/2022 4:00:00 AM<p>​<span style="font-size:11pt;">CMS began surveying against <a href="" data-feathr-click-track="true" target="_blank">Phase 3 of Requirements of Participation for Nursing Homes</a> on October 24, 2022. With 180 pages of guidance, revisions, and updates affecting 52 F-tags, many providers are feeling anxious about compliance with the new guidance.  </span></p><div><span style="font-size:11pt;">Angie Szumlinski, Director of Risk Management for HealthCap, recently spoke with Crystal Bowens, Associate AHCA/NCAL VP of Regulatory Services, about the updates. You can hear from these in​dustry experts by listening to the free podcast <a href="" data-feathr-click-track="true" target="_blank">here</a>. As a reminder, AHCA/NCAL members can always reach out with their compliance questions via email <a href="" data-feathr-click-track="true" target="_blank">at​</a>. </span><br></div>CMS began surveying against Phase 3 of Requirements of Participation for Nursing Homes on October 24, 2022.
AHCA/NCAL Reacts to the Biden Administration’s Plan to Strengthen Oversight of Poorest-Performing Nursing Homes’s-Plan-to-Strengthen-Oversight-of-Poorest-Performing-Nursing-Homes.aspxAHCA/NCAL Reacts to the Biden Administration’s Plan to Strengthen Oversight of Poorest-Performing Nursing Homes10/21/2022 4:00:00 AM<p><br></p><strong>WASHINGTON, D.C.</strong> —  Today, the American Health Care Association and National Center for Assisted Living (AHCA/NCAL), representing more than 14,000 nursing homes and assisted living communities across the country that provide care to approximately five million people each year, released a statement in reaction to the Biden Administration’s announcement on strengthening oversight of the Center for Medicare and Medicaid Services’ (CMS) Special Focus Facilities program for nursing homes.<br><br>The statement is attributable to Mark Parkinson, president and CEO at AHCA/NCAL:<br><br>“We appreciate some of the steps the Biden Administration is making today to address the small portion of chronically, poor performing nursing homes as well as grant opportunities to help address our long term care labor crisis. However, we remain concerned that the rhetoric surrounding these reforms is degrading to the millions of nursing home caregivers who are committed to caring for their residents like their own family and have risked their lives serving on the frontlines during this pandemic. <br><br>“Residents are not victims of the nursing home industry. Too many were victims of a vicious virus that targets the elderly as well as terrible public policy decisions—made by both parties—that failed to support and prioritize our most vulnerable. We hope to work with the Administration to fully appreciate the role of nursing homes in our nation’s health care system, the dedication that our caregivers have to their residents, and the need for policy that pushes improvement, not punishment.<br> <br>“The Special Focus Facilities program is supposed to identify facilities in need of improvement and assistance. Escalating citations and penalties have neither helped turn these facilities around nor prevented other facilities from becoming chronic poor performers. Last year, we proposed substantial <a href="/Advocacy/Pages/Care-For-Our-Seniors-Act.aspx" data-feathr-click-track="true">reforms</a>, including a <a href="/Advocacy/Documents/Poor-Performing-Facilities.pdf" data-feathr-click-track="true" target="_blank">five-step process</a> on how to address chronic, poor performing nursing homes. The survey system needs to adopt this process to make meaningful changes for the residents in these facilities.” <br> <br>“Meanwhile, much more is needed if we wish to rebuild and expand the long term care workforce. Nursing homes have experienced the <a href="/News-and-Communications/Fact-Sheets/FactSheets/BLS%20JULY%202022%20JOBS%20REPORT.pdf" data-feathr-click-track="true" target="_blank">worst job losses</a> of ​any ​health care sector. Analysts​ have projected that it will require <a href="/News-and-Communications/Press-Releases/Pages/Report-Increasing-Nursing-Home-Staffing-Minimums-Estimated-at-$10-Billion-Annually.aspx" data-feathr-click-track="true">billions of dollars</a> to hire more than one hundred thousand more nurses and nurse aides if a federal staffing minimum moves forward. Long term care needs a concerted and considerable investment to recruit and retain more frontline caregivers and address access to care issues for millions of seniors.”  <br><div><br></div>AHCA/NCAL released a statement in reaction to the Biden Administration’s announcement on strengthening oversight of the Center for Medicare and Medicaid Services’ (CMS) Special Focus Facilities program for nursing homes.


Phase 3 Interpretive Guidance – Delayed

Phase 3 of the Requirements of Participation (RoP) went into effect on November 28, 2019. However, as the Centers for Medicare & Medicaid Services (CMS) announced in a memo (QSO-20-03-NH) released on November 22, 2019, CMS will not be releasing the interpretive guidance (IG) for Phase 3 until the second ​quarter of 2020.  Read More>>​