Ask the payment expert ... about the observation stay loophole
Ask the payment expert … about the observation stay loophole

I recently attended a workshop that said that Phase 3 goes into effect this November. I thought it was November 2019. Which is right?

You are correct. The Requirements of Participation (RoP) Phase 3 requirements are in effect Nov. 28, 2019. Although they go into effect in 2019, you have a lot of preparation to complete prior to that time.

Key areas that will go into effect in 2019 are Trauma Informed Care, QAPI/QAA Data Collection and Monitoring, Infection Preventionist, Compliance and Ethics program and training requirements.

First, programs are being offered now to assist you in understanding federal regulators’ focus on behavioral health, including new guidance for staffing and training, behavioral difficulties and dementia care. Trauma informed care will require your staff to have some expertise in how to identify and how to response to your individual residents with issues such as post traumatic stress disorder, substance abuse, late effects of trauma, etc.

We suggest you have someone attend your state dementia and crisis management program so they can be training your staff.

The QAPI/QA process will expand to include your board and owners responsibility and oversight of your program. If you have not yet made that shift, you need to begin by informing your board of their responsibility and putting QAPI processes in place in your facility. Find more information in the RoP – F866.

An infection control preventionist will be required to have professional training, education, work at least part-time in the facility and have completed specialized training in infection prevention and control. Review F882 for specific requirements.

The time to begin identifying the staff and finding training is now.

Please send your payment-related questions to Patricia Boyer at [email protected].