Nursing facilities must comply with voluminous regulations. Late last year, CMS rewrote the most comprehensive of these, the nursing facility Requirements of Participation (RoPs). The rewrite marks the first comprehensive revisions to the RoPs since 1991. CMS published the new RoPs in a final rule, coined the “Mega Rule,” which CMS is implementing in three phases. This presentation will primarily focus on Phase 2 of the new RoPs, which become effective November 28, 2017. This presentation will address “what’s changed” with the RoPs and provide participants information on how to address “what’s next.”

1. Mega Rule’s Mega Impact
on Nursing Facilities:
The New Requirements
of Participation
00

2. Agenda/Objectives
Overview
of Changes
Timeline Implementation
of Changes
01

3. CHANGE 02

4. 0303

5. Phase 1 Phase 2 Phase 3
Effective
2016
NOV 28
Effective
2017
NOV 28
Effective
2019
NOV 28
04

6. monthly
drug
regimen
review 05

7. Quality Assurance and Performance Improvement
06

8. SNF HOME
07

9. BASELINE
CARE PLAN
08

10. Care Plan Summary
09

11. Facility
Assessments
The facility’s
resident population
The facility’s resources
A facility-based and
community-based risk
assessment
10

12. Behavioral
Health
Services
11

13. 12

14. arbitration updates
third-party guarantees
compliance and
ethics programs
13

15. 14

16. 15

17. Thank you!
Alicia Blumenfeld Chandler
General Counsel
Continuing Care Division
Trinity Health
-
chandlea@trinity-health.org
Andrea Nicole Lee
Attorney
Health Care Practice Group
Honigman Miller Schwartz and Cohn
-
alee2@honigman.com
16