With little more than a month before some Phase 3 measures are set to take effect, providers are calling on the Centers for Medicare & Medicaid Services to delay enforcement of all measures under the final phase of the Requirements of Participation due to a “lack of guidance.” 

LeadingAge President and CEO Katie Smith Sloan made the request Friday in a letter to CMS Administrator Seema Verma. The correspondence said the lack of guidance puts nursing facilities in an “untenable position” and is bound to lead to “wide variations” in citations on Phase 3 requirements. 

“Time now is too short for nursing homes and state survey agencies to be up to speed on Phase III by the rapidly approaching deadline. Quality nursing home care is important to all of us. Nursing homes and state agencies want to do a good job and fulfill their responsibilities to the best of their abilities,” Smith Sloan said in a statement. 

“Please honor and facilitate that outcome by extending the Phase III deadline to give all of us a reasonable opportunity to be ready to comply with these requirements,” she added. 

Enforcement of Phase 3 RoP measures regarding trauma-informed care, infection preventionist and staff competency are expected to start Nov. 28, while other provisions received a one-year delay

But CMS has still not spelled out how compliance will be assessed on requirements involving person-centered care planning; trauma informed care; behavioral health services; infection preventionists; compliance and ethics programs; physical environment; training requirements and competencies of staff; and monitoring dietary, LeadingAge wrote. 

Smith Sloan added that providers and surveyors have been “working in the dark” while trying to prepare for the final phase.