Ask the Nursing Expert about ... documentation for new survey regulations

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Judi Kulus, VP of Curriculum Development, AADNS
Judi Kulus, VP of Curriculum Development, AADNS

For years I have referred to the State Operations Manual (SOM) Appendix P for guidance on the survey process. But the Centers for Medicare & Medicaid Services recently announced that Appendix P will be archived and not updated with the new survey process instructions. Where is the most relevant documentation that explains the new survey regulations and process?

The new survey process guidelines are on a new CMS Survey Process website ( Provider-Enrollment-and-Certification/GuidanceforLawsAndRegulations/Nursing-Homes.html), which contains complex new survey process documents. Four documents in particular should be downloaded, reviewed and incorporated in nursing facility care systems.

The first link in the download section is Appendix PP of the State Operations Manual. This document is over 700 pages long and outlines how surveyors will evaluate nursing facilities on more than 200 possible deficiencies.

The new survey process logistics are outlined in the Long Term Care Survey Process (LTCSP) Procedure Guide. In effect, this tool replaces the formerly relied upon Appendix P. This resource outlines how the new survey process works.

Finally, on the new CMS survey website are links to two zip files. Every nurse leader should open these to access the LTC Survey Pathways and the LTCSP Initial Pool Care Areas. These two files contain critical, detailed forms that surveyors will use to assess each nursing facility's compliance to the requirements of participation in Medicare and Medicaid programs.

Review and save these four documents to ensure that you are knowledgeable enough to defend your facility practice at a moment's notice if cited.

Please send your nursing-related questions to Judi Kulus at