The Centers for Medicare & Medicaid Services (CMS) has announced an additional delay in the implementation of its updated nursing home surveyor guidance. Initially set to take effect on March 24, 2025, the revised guidelines will now be enforced starting April 28, 2025. The delay was communicated in a revised memo released on March 10, 2025.
This extended timeline aims to provide more time for nursing home providers and surveyors to receive adequate training and prepare for the updated guidance. These revisions, which are intended to enhance the oversight of long-term care facilities, will focus on key areas such as medication use, staffing levels, and quality of care, with particular emphasis on nursing services and Payroll-Based Journal (PBJ) data.
The updates cover several critical areas, including:
- Admission, Transfer, and Discharge
- Unnecessary Psychotropic Medication and Chemical Restraints
- Resident Assessment
- Nursing Services
- Quality of Life and Care
- Infection Prevention and Control
- Quality Assurance Performance Improvement (QAPI)
- Additional areas of nursing home operations
CMS has indicated that training materials and resources, including the revised guidance for nursing services and PBJ, will be made available ahead of the new implementation date. Surveyors will also be provided with updated Critical Element Pathways and access to the revised Appendix PP of the State Operations Manual.
CMS has already made the updated training publicly available on the Quality, Safety, and Education Portal. This includes detailed instructions on how surveyors should assess staffing levels, particularly through the use of PBJ data, prior to conducting on-site inspections.
Nursing homes are encouraged to continue reviewing and preparing for the updated guidance, ensuring compliance with the new focus on staffing, medication use, infection control, and overall care quality.
The revised guidance can be accessed here.
Compliance Perspective
Issue
CMS’s 2025 Mission and Priorities Document (MPD) outlines several key enforcement priorities for nursing homes, including the management of antipsychotic medications, involuntary discharges, nurse staffing, and PBJ reporting. With the delay in the implementation of updated guidance until April 2025, nursing homes now have additional time to ensure full alignment with the revised CMS standards. Facilities must prioritize adjustments to policies, staff training, and audits to remain in compliance once the new surveyor priorities take effect. Ensuring these changes are made proactively will help prevent penalties and ensure high-quality care.
Discussion Points
- Facilities should review and update their policies and procedures to align with CMS’s 2025 enforcement priorities. This includes ensuring compliance with updated diagnostic and reporting requirements for antipsychotic medication use, as well as refining procedures to assess and document resident needs before admission to prevent involuntary discharges. Additionally, staffing procedures should be revised to ensure accurate PBJ reporting and adherence to staffing requirements.
- Provide training for all relevant staff on the updated CMS requirements. The training should cover proper documentation and management of antipsychotic medications, strategies for assessing and preventing involuntary discharges, and accurate reporting of staffing levels through the PBJ system.
- Conduct regular audits to assess current practices related to antipsychotics, nurse staffing, and PBJ reporting. Audits should focus on medication management, discharge procedures, and staffing levels, ensuring any discrepancies are addressed promptly. Auditing processes should also verify that policies and training have been implemented correctly, with corrective actions taken where necessary.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*
