United States

Senior Living Health Care Connection: Prepare for ROP phase 2


Phase 2 of the Centers for Medicare and Medicaid Services requirements of participation (ROP) implements a new survey process effective Tuesday, Nov. 28, 2017. This new process incorporates the traditional survey process, and the quality indicator survey used in a majority of states. Skilled nursing and nursing facilities can expect new F-tags. After extensive training at the regional and state survey management level through July 2017, state agency surveyors will be trained via computer-based interactive training Sept. 5–8, 2017. The surveys will be computer based using the software that has been designed to capture facility information in a structured autonomous survey process.

Facilities should become acquainted with some of the main changes, including:

  • The restructured and updated language relating to resident rights
    • Replace the term “legal representative” with “resident representative”
    • Ensure each resident understands his or her right to physician choice and ensure that those physicians are credentialed
    • Ensure resident is provided the opportunity to sign off on the care plan and any changes to the care plan
    • Appoint a grievance official to oversee resident grievance
  • The phrase, “freedom from abuse, neglect and exploitation” includes all staff, including professional staff
    • Facility cannot employ individuals who have had disciplinary action taken against their license by a state licensure body for abuse, neglect, mistreatment of residents or misappropriation of resident property
    • Establish policies and procedures relating to proper reporting of crimes 
  • Admission, transfer and discharge rights
    • Provide information to residents and their representatives regarding:
      • Post discharge plans and follow-up
      • Right to remain or return to the facility
      • Right to due process for discharges and transfers
    • Develop a discharge planning template 
  • Resident assessment requirements
    • Include food service providers and nurse aides in the care planning process 
  • Nursing services
    • Staffing levels include competency and skills test requirements
    • Competency and skills test also refer to food service staff 
  • Pharmacy services
    • A pharmacist must review the resident chart during the monthly regimen review 
  • Quality
    • Be familiar with the facility’s quality assurance and performance improvement (QAPI) program and have it available to surveyors
    • In 2019, during phase 3, facilities will have to show implementation of the QAPI program. 
  • Infection prevention and control program which helps prevent the development and transmission of communicable diseases and infections
    • Facilities must have an antibiotic stewardship program in place that includes antibiotic use protocols and a system to monitor antibiotic use
    • In 2019, during phase 3, facilities must have a certified or trained preventionist on staff 

These are only a few of the changes to the ROP for skilled nursing facilities. Providers are encouraged to read the actual final rule to fully understand implementation of these reforms. Access the Federal Register website to learn more.

For more information, contact Joan McCarthy at +1 312 634 3479.

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