Regulatory Recap
August 2025
CMS Revised Long Term Care Survey Guidance

As we start off 2025, it is important to review any changes that will take place with regards to CMS surveys and other regulatory updates. The CMS has updated the survey guidance and revised the State Operations Manual that will be effective as of February 24, 2025. Surveyors will begin using the new guidance for all surveys as of the above effective date. The goal is to streamline the survey process and eliminate overlapping citations. The following are some of the guidances that have been revised. Your team should review and ensure that changes in your processes have been made to maintain compliance with new standards.

Admission/Transfer/Discharge

  • Tags F622-F626, F660-661 will be deleted, and revisions were made to noncompliant transfers and discharges.
  • Tag F627 for Inappropriate transfers and discharges along with tag F628 for the transfer and discharge process will be the new citations with the goal to better identify where transfers and discharges were not carried out to meet resident rights and regulatory requirements. Changes were also made to verbiage requirements of admission agreements where certain language around payment guarantees cannot be included.

Chemical Restraints/Unnecessary Use of Psychotropic Medication

  • The former F758 tag for unnecessary use of psychotropics has been incorporated into F605 to streamline and strongly advise facilities to prevent the unnecessary use of psychotropics.
  • The guidance is revised to include situations where medications are used to cause sedation as unnecessary. The resident must be informed and included in the initiation or increase of psychotropic medication and has the right to accept or decline the medication.
  • The F757 tag for unnecessary medications has been revised to include only non- psychotropic medications to avoid confusion and separation of the types of medications.

Professional Standards and Medical Director

  • Clarification regarding medical director responsibilities was added and F841 now includes implementation of resident care policies, participation in the quality assessment and assurance committee, and addressing issues related to coordination of medical care and active involvement in conducting facility assessments.

Accuracy/Coordination/Certification

  • Modifications to guidance related to minimum data set (MDS) assessments accuracy and documentation.
  • New instructions include investigating if proper documentation supporting a medical condition specifically where a resident is receiving an antipsychotic medication. The documentation should comply with the facility policy and regulatory requirements.
  • Due to this revision, F642 (coordination/certification of assessment) is being deleted and added to F641 (accuracy of assessment) for better clarity.

QAPI/QAA Improvements

  • New guidance was added to include health equity when collecting and monitoring data.
  • Facilities should consider factors that affect health equity and outcomes of their resident population specifically when creating their QAPI program priorities.
  • QAPI now should also include interviewing the medical director.

Infection Prevention and Control

  • Use of Enhanced Barrier Precautions for Prevention of multidrug-resistant organisms is now included as part of deficiency- F880.
  • COVID-19 immunization is now included with requirements for facilities to educate residents and staff on the benefits and potential side effects of the vaccine.