Requirements of Participation Update from LeadingAge National RoPs Proposed Rule

Requirements of Participation Update from LeadingAge National RoPs Proposed Rule

The RoPs proposed rule “Regulatory Provisions to Promote Efficiency and Transparency” has not been finalized. The comment period closed on September 16 and CMS cannot predict when this rule will be finalized. For this reason, none of the changes that were proposed in the rule are in effect. Providers must continue to meet all Requirements of Participation as written.

Requirements of Participation, Phase 3:

RoPs 3 will be implemented on November 28, 2019. Although the rule proposed to delay requirements for 2 sections of RoPs 3 (Quality Assurance & Performance Improvement and Compliance & Ethics), this delay is not in effect because the rule has not been finalized. Providers must be prepared to implement the requirements of Phase 3 in November as written.

Phase 3 Guidance:

CMS has not released interpretive guidance on Phase 3 yet. Though CMS initially planned to release guidance this past summer, they say there is currently a delay and cannot predict when the guidance will be released.

Because of the delay in guidance and the uncertainty of the proposed rule, LeadingAge will not be releasing a Compliance & Ethics toolkit at this time. We will continue to work with our partners and experts for a future release once this section of the RoPs has been finalized. In the meantime, we encourage providers to refer to our RoPs resources, including the Trauma-Informed Care toolkit and the Staff Competency Toolkit©, both available at the link below, to prepare for RoPs 3 implementation on November 28, 2019.

 

Nursing Home RoPs resources

Nursing Home RoPs resources

 

https://www.leadingage.org/nursing-home-rop-tools-and-resources-0

Questions? Contact: Laura Hofmann, MSN, RN. Director of Clinical and Nursing Facility Regulatory Services * Lhofmann@LeadingAgeWA.org