Seema Verma

Despite a push from the post-acute care industry to delay implementation of Phase 2 requirements of participation guidelines under the Centers for Medicare & Medicaid Services, providers at press time were still planning to be ready to go with them on Nov. 28.

Although most of the requirements don’t need to be implemented until Phase 3 in 2019, Phase 2 deadlines that do hit late this month include having a QAPI plan that can be submitted to the surveyor, having an antibiotic stewardship program and understanding a new survey process, which includes new F-Tags. 

CMS said that it is delaying enforcement penalties for a year. If facilities are not in compliance with the new requirements, CMS would use the year to “educate” facilities by requiring a plan of correction, the agency said. Enforcement of Phase 1, which began last November, is still fully in effect.