Lisa Thomson


As leaders in post-acute care, we need to stay abreast of the regulatory changes and its impact on our operations. In healthcare the one thing that remains consistent is change! Effective December 1, 2012, there are a series of Survey and Certification Memorandums from CMS that affect clinical provision of care as well as survey process changes.

Indicated below are the links to the S&C Memorandums as well as a brief description. While these are not new F-Tags, the changes are reflected in the interpretive guidance’s, investigative protocols – affecting survey process, definitions, polices, integration of care as well as staff training and competency around these changes. It’s critical to share these changes with your staff in order to ensure compliance.

S&C 12-44-NH – The Hand in Hand training series related to dementia has been mailed free to all nursing homes, Regional Offices (RO) and State Survey Agencies.  This is part of the national dementia awareness and training initiative.  Dementia training also is a priority of industry groups.

Learn more.

S&C 12-45-NH – Update to Survey Process to reflect MDS 3.0
These highlights include changes to the survey process: Specifically, changes to focus, quality measures reports, and outstanding complaints; initial tour modified to recognize resident’s personal preferences; licensed nurse schedules during survey; a need to provide an entire admission packet; a list of all residents who are receiving or have received antipsychotic medications over the past 30 days. A minimum of four must be reviewed by surveyors, which is new, along with changes to CMS 672 and CMS 802. The interviewable resident criteria should reflect MDS 3.0 definitions. Learn more.

483.10(b)(4) and (8)Rights Regarding Advance Directives, Treatment, and Experimental Research (F155)

These highlights are advanced care planning, which has a NEW definition and processes, advanced directives and a facility’s new responsibilities, NEW resident choice and preferences, survey guidance and process changes, revised health practitioner and physician processes. Learn more.

483.25 End of Life (F309) – These highlights include advanced care planning, which has – NEW definition and processes; imminent dying processes and definition; NEW definition for palliative care; integration of hospice services and coordination plan of care. It also include a NEW ABCDE Mnemonic. Learn More> <

483.25 Naso-Gastric Tubes (F322 Feeding Tubes) — These highlights include the Avoidable/Unavoidable use of a feeding tube; benefits, risks, decision to use feeding tubes; assessment processes and protocols for technical aspects of feeding tubes; protocols for nutritional aspects of feeding tubes, NEW calibration of enteral feeding pumps – NEW; and NEW survey guidance and investigative protocols.  Learn more.

As leaders in long term care, it is imperative to prepare your operations and clinical teams for these changes.

Lisa Thomson, LNHA, is the vice president of Pathway Health Services.