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RoP Phase 3 Information Released

The Centers for Medicare & Medicaid Services (CMS) is proposing to delay Phase 3 of the Requirements of Participation (RoPs). All items in Phase 3 will be delayed except for the requirements related to the Infection Preventionist at §483.80(b)(1) through (4) and (c) and §483.75(g)(1)(iv) (participation of Infection Preventionist on the quality assessment and assurance committee).

CMS is also proposing revisions to Phase 1 and 2 RoP language. Ombudsman notification of emergency hospital transfers will no longer be required. The original RoP language did not meet the intended objective of reducing inappropriate discharges. Facility-initiated transfer and discharge language created the unintended consequences of increasing administrative burden while failing to improve care. CMS is proposing to resolve this by changing the language. The language will state “facility-initiated” involuntary transfer or discharge is a transfer or discharge that the resident objects to, did not originate through a resident’s verbal or written request, and/or is not in alignment with the resident’s stated goals for care and preferences.  

Although psychotropic use will continue to be a focus, CMS recognized the burden of requiring a physician to assess the resident prior to re-ordering a 14 day PRN order. CMS is proposing to remove the requirement that a physician see the resident in order to re-order an anti-psychotic medication every 14 days. Instead, the physician may give a verbal order.

Stephanie DeWees, Quality & Regulatory Specialist for Long Term Care, has compiled a complete summary of what is in the Federal Register currently and an in-depth analysis of the proposed changes providers should focus on.  

Questions regarding the RoP Phase 3 changes should be directed to Stephanie at or call 614-545-9034.

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