Call to Action: Comment Now on How RoP Affect You and Your Residents

CMS has requested feedback specific to areas that may pose an unrealistic burden to your nursing facility. THCA is asking all members to submit comments to CMS by June 25, 2017 regarding the Requirements of Participation.

The following areas you may want to comment on:

  • Addition of new policies and procedures including requirements that certain topics must be included;
  • The facility assessment;
  • Behavioral health services;
  • The specific regulatory detail related to the compliance and ethics program;
  • Additional transfer/discharge notifications required to be sent to the Long-Term Care Ombudsman;
  • New two-hour reporting requirement for “injuries of unknown source:”
  • New resident room and bathroom requirements for facilities newly certified or constructed after Nov. 28, 2016;
  • The details associated with the grievance process and how this differs from a facility’s complaint process;
  • Required detail for a facility’s Quality Assurance and Performance Improvement (QAPI) program; and
  • The requirements to, upon request, provide surveyors with documentation and evidence of the facility’s QAPI program and compliance with requirements. In order for comments to be considered appropriate, be specific to the regulation you are commenting on and explain:
  • How it relates to your work;
  • How it impacts your workflow process; and
  • How it impedes your ability to provide quality care to your residents

You are strongly encouraged to use your personal experience as you have attempted to implement the new Requirements of Participation. For example, clinical issues would be best commented on by a nurse.

To submit online comments:

  • Click here to access CMS comment webpage and enter your comment in the dialogue box that immediately appears.
  • You will then need to provide information for your comment to be accepted. If you wish your comment to be submitted anonymously, you only have to submit your State, Zip, and Country. Your City and State will appear on CMS’s website, all other information will be kept private.