The Centers for Medicare & Medicaid Services (CMS) recently released its 2025 Mission and Priorities Document (MPD), outlining key priorities and enforcement areas for nursing homes in the upcoming year. Nursing homes will see several important updates that may affect their compliance efforts. CMS’s 2025 enforcement priorities include antipsychotic medications, involuntary discharges, nurse staffing, and Payroll-Based Journal (PBJ) reporting.
The management of antipsychotic medications continues to be a significant area of emphasis, with CMS stressing the need for accurate diagnoses and appropriate use, particularly in light of past issues with misdiagnoses, such as the overdiagnosis of schizophrenia. This emphasis on accurate diagnosis is critical, as improper use of antipsychotic medications can lead to harmful side effects and inadequate care for residents. CMS is also updating the Resident Assessment Instrument User’s Manual to strengthen requirements in this area.
Involuntary discharge remains a key focus for CMS, highlighting the need for facilities to carefully assess their ability to meet the needs of incoming residents before accepting admissions. Failure to assess this properly can lead to negative outcomes and strained relationships with hospitals. CMS also emphasized its continued focus on nurse staffing levels and the accuracy of PBJ reporting. Ensuring compliance with staffing requirements and accurate reporting is crucial for nursing homes to avoid penalties.
In addition to these priorities, CMS has revised its survey guidance in several other areas. These include new criteria for the Hospice Special Focus Program, revised guidance for Home Health Agencies (HHAs), and updated long-term care surveyor guidance in Appendix PP. Furthermore, CMS has issued new guidelines on enhanced barrier precautions for long-term care, which aim to protect residents from infections. CMS is also testing a risk-based survey process for long-term care facilities. Revisions to guidance for ESRD facilities, transplant programs, and community mental health centers are also part of the 2025 updates.
Nursing homes will need to carefully review the updated guidance to ensure they remain in compliance with CMS’s revised standards. They should focus on areas such as medication management, staffing, and accurate reporting. The updated guidelines will be available in Appendix PP of the State Operations Manual beginning in February, and will be accessible to surveyors in the Automated Survey Process Environment (ASPEN) system starting February 24.
Compliance Perspective
Issue
CMS’s 2025 MPD outlines several key enforcement priorities for nursing homes, including the management of antipsychotic medications, involuntary discharges, nurse staffing, and PBJ reporting. As these areas are closely scrutinized in 2025, nursing homes must ensure they are fully aligned with the updated CMS standards to avoid penalties and ensure high-quality care. This will require adjustments in policies, staff training, and regular audits.
Discussion Points
- Facilities should review and revise their policies and procedures to align with CMS’s updated 2025 enforcement priorities. This includes ensuring compliance with updated diagnostic and reporting requirements for antipsychotic medication use. Additionally, facilities should thoroughly assess and document their ability to meet the needs of incoming residents before admission, to prevent involuntary discharges. Review nurse staffing procedures to guarantee that adequate staffing levels are maintained and accurately reported via the PBJ system.
- Train all relevant staff on the updated CMS requirements, including proper documentation and use of antipsychotic medications, assessment procedures to prevent involuntary discharges, and meeting staffing requirements. Additionally, staff should be educated on the correct use and reporting of the PBJ system.
- Audits should focus on the use of antipsychotics, nurse staffing, and PBJ reporting. Periodically review medication management practices, discharge documentation, and staffing levels, addressing any discrepancies promptly. Additionally, audits should ensure effective implementation of policies and training, with corrective actions taken when issues arise.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*
