Long-term care providers have 18 months to adapt to some of the Phase 2 requirements of participation without facing penalties, the Centers for Medicare & Medicaid Services announced in late November.

CMS had previously announced postponement of enforcement penalties for a year, but the 18-month enforcement moratorium applies to a few “unique and separate” F-Tags.

These are F-655 – Baseline Care Plan, F-740 – Behavioral Health Services, F-741 – Sufficient/Competent Direct Care/ Access Staff-Behavioral Health, F-758 – Psychotropic Medications related to PRN Limitations, F-838 – Facility Assessment, F-881 – Antibiotic Stewardship Program, F-865 – QAPI Program and Plan related to the development of the QAPI Plan, and F-926 – Smoking Policies.

Noncompliance with these tags will still be cited by surveyors, CMS noted. The penalty moratorium, along with a delay on Nursing Home Compare’s health inspection rating, reflects a “temporary need to accommodate” major regulatory changes, CMS said.