January 17, 2025
The Centers for Medicare & Medicaid Services (CMS) has announced updates to the revised nursing home surveyor guidance initially released in November 2024. These updates encompass revised guidance and training for nursing services and the Payroll-Based Journal Staffing Report. Additionally, CMS is extending the implementation of all revised surveyor guidance to March 24, 2025, as detailed in QSO-25-12-NH. This comes after the initial implementation deadline was set to take place in February upon the release of CMS’ initial key revisions to the guidance.
CMS’ newly revised guidance includes updates to FTag727:
- Sufficient Nursing Staff, RN 8 Hrs./7days/Wk., Full Time DON, & Payroll-Based Journal: Guidance for investigations using the Payroll-Based Journal Staffing Data Report has been added. This report will be used as one of the sources of information indicative of potential noncompliance. Instructions specific to staff interviews, observations, key elements of noncompliance, and deficiency categorization are also added to the guidance. Instructions to surveyors based on whether or not the report identified concerns were added to the guidance. Investigative probes for the director of nursing (DON) requirements and deficiency categorization examples, as well as investigative procedures for evaluating compliance with the submission of direct care staffing information and payroll using the Payroll-Based Journal Staffing Data Report, were added to the guidance.
PALTmed is actively working on developing and refining tools and guides to help members navigate these changes. Stay tuned for updates, including new medical director guidance, an updated Synopsis of Federal Regulations, informative podcasts, and more on the revised guidance.
