How Phase 2 of CMS guidelines impact registered dietitians

CMS: Reform of Requirements for Long Term Care Facilities

The Department of Health and Human Services along with The Centers for Medicare and Medicaid Services (CMS) published a reform of requirements for long-term care facilities (42 CFR part 483, subpart B) that became effective on November 28, 2016. This includes revised and expanded Dietary Services Title to §483.35 to Food and Nutrition Services §483.60.

Among this reform, there is a three-part “phase-in” implementation that occurs from 2016 through 2019. CMS decided to release the updates in phases to ensure that State Survey Agencies, long-term care facilities, and the public has enough time to become familiar with the updates and how they will be surveyed with the new information.

Implementation dates:

• Phase 1: November 28, 2016
• Phase 2: November 28, 2017
• Phase 3: November 28, 2019

What are the updates to Phase 2 of the revisions?

CMS revised the nursing facility F-tags to match the new regulations

The above image shows an example of the original F-Tag and the revised new F-Tag. Some tags were combined, and some tags were split into multiple subparts.

New, computer-based long-term care survey processes (combines Traditional and QIS).

• During previous surveys, there were two different processes that surveyors used to review the facility:
  • Traditional – Survey team gathers data and records findings on paper. Findings are transferred to an electronic version and then deficiencies are recorded on CMS-2567.
  • Quality Indicator Survey (QIS) – Each member of the survey team uses a PC tablet during the survey process to record his or her findings that are eventually incorporated and organized by specific QIS software.
• Goals of the New Survey Process –
  • Same survey nationwide
  • Computer-software based
  • More effective and efficient

Why are these updates important/pertinent to RDs/RDNs?

• Dietitians are now considered an integral part of interdisciplinary team
• More innovative approaches to survey (most have been the same since the early 90s)
• New regulations and policies align with national health and safety standards
• Simplified rules and policies for clinicians and providers
• More consistency (nationwide) from survey teams
• Resident-centered care focus
• Increased continuity and timeliness of care

Overall, the CMS updated guidelines are not only a positive change for long-term care facilities, but also to the care dietitians provide to residents on a daily basis.

For further information about these updated guidelines, FAQs, and training resources, go to https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/GuidanceforLawsAndRegulations/Nursing-Homes.html

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References:

Final Rule. Centers for Medicare and Medicaid Services (CMS), HHS. https://www.federalregister.gov/documents/2016/10/04/2016-23503/medicare-and-medicaid-programs-reform-of-requirements-for-long-term-care-facilities. Updated October 4, 2016. Accessed March 13, 2018.

Handy, Linda. Mastering Title 22, CA Codes, and New Survey Procedures in Dietary Services

Nursing Homes- Medicare and Medicaid Programs; Reform of Requirements for Long-Term Care Facilities. Centers for Medicare and Medicaid Services.

https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/GuidanceforLawsAndRegulations/Nursing-Homes.html

Updated February 6, 2018. Accessed March 19, 2018.