Navigating the 2025 CMS Updates: Key Changes for Long-Term Care Facilities

 This article is Part 3 in a 4-part series to explain the CMS changes for LTC facilities and actionable steps for compliance. Read Part 1 and Part 2. This article focuses on professional standards, infection prevention and control and health equity and QAPI/QAA improvement.

CMS regularly updates guidance to address emerging trends in deficiency citations across the nation, focusing on enhancing resident health, safety, and quality of care. The following information is intended to help State Survey Agencies (SAs), long-term care facilities, and the public better understand how compliance will be evaluated and provides an overview of the changes and recommendations for how to best ensure compliance.

Professional Standards for Medical Directors

Medical directors now have expanded their responsibilities under updated guidelines. These include ensuring compliance with facility care policies, monitoring physician adherence, and addressing documentation gaps for antipsychotic prescriptions. The guidelines, updated under Professional Standards (F658), emphasize scrutiny of residents diagnosed with conditions lacking sufficient documentation to justify the use of antipsychotic medications. Nursing homes must integrate these standards into staff education and quality assurance efforts to remain compliant. The Medical Director is tasked with ensuring that physicians follow facility policies on diagnoses and prescriptions, while also overseeing care coordination and the implementation of resident care policies. Additionally, interviews with the facility Medical Director are now part of the Unnecessary Medications and Quality Assurance & Performance Improvement (QAPI) pathways.

Action Steps

1. Educate Physician and Staff

• Educate Medical Director, attending physicians and nurses on F658 Updates: Provide targeted training on documentation standards, medical necessity, and prescribing practices.

2. Enhance Medical Director Oversight

• Monitor Physician Compliance: Implement a process for the Medical Director to review physician prescribing patterns, particularly for antipsychotic medications.
• Verify Proper Documentation for Antipsychotics: Implement a review process to ensure that diagnoses justify antipsychotic prescriptions.
• Conduct Regular Physician Meetings: Hold routine check-ins with attending physicians to reinforce expectations and address non-compliance.
• Engage the Medical Director in QAPI Meetings: Ensure the Medical Director actively participates in QAPI discussions related to medication use, care policies, and physician adherence.

 3. Physician Accountability

• Develop a Physician Compliance Monitoring System: Implement a system to track physician prescribing patterns and adherence to facility policies.
• Ensure Clear Communication on Policy Expectations: Provide direct feedback to physicians regarding necessary improvements in documentation and prescribing.

4. Prepare for Survey Inspections – Mock Survey

• Conduct mock surveys focusing on the enhanced Medical Director responsibilities.
• Implement corrective actions and re-educate staff based on findings.

Infection Prevention and Control and COVID-19 Immunization

Infection prevention and control remains a central focus for CMS, with significant updates in this area. Revised guidance introduces enhanced barrier precautions aimed at reducing the transmission of multidrug-resistant organisms (MDROs), underscoring the importance of proactive and consistent measures to protect both residents and staff. These updates reflect CMS’s ongoing commitment to improving safety and care quality in nursing homes. Additionally, facilities are now required to educate residents, their representatives, and staff about the benefits and potential side effects of the COVID-19 vaccine, as well as to offer the vaccine.

Action Steps

1. Implement Enhanced Barrier Precautions (EBPs)

• Review and Update Infection Control Policies: Align facility policies with CMS’s enhanced barrier precautions (EBPs) to reduce multidrug-resistant organism (MDRO) transmission.
• Train Staff on EBP Protocols: Educate staff on when and how to apply gowns and gloves during high-contact resident care activities, even when standard precautions may not typically require them.
• Ensure Readiness for Surveyor Observations: Conduct spot-checks to ensure staff are correctly implementing EBPs and following proper PPE usage.
• Monitor Compliance and Address Gaps: Conduct routine audits of infection prevention practices and provide immediate feedback.

2. Improve Multidrug-Resistant Organism (MDRO) Prevention Measures

• Implement Screening and Surveillance: Establish protocols for early identification of residents at risk for MDRO colonization or infection.
• Enhance Environmental Cleaning Protocols: Increase the frequency and effectiveness of cleaning high-touch surfaces and shared equipment.
• Reinforce Hand Hygiene Practices: Conduct inconspicuous regular hand hygiene audits and re-educate staff on proper techniques.

3. Educate Residents, Families, and Staff on COVID-19 Vaccination

• Develop and Distribute Educational Materials: Provide clear, accessible information on the benefits, risks, and side effects of the COVID-19 vaccine.
• Offer Vaccine Discussions with Medical Staff: Ensure residents and their representatives have opportunities to ask questions about vaccination.
• Document Vaccine Offerings and Informed Consent: Maintain records of vaccine acceptance or refusal, along with documented education efforts.
• Track and Monitor Vaccination Rates: Establish a process for monitoring vaccination rates among residents and staff and address any barriers to vaccination.

4. Strengthen Infection Preventionist (IP) Oversight

• Ensure Infection Preventionist Engagement: The IP should oversee EBP implementation, vaccination efforts, and infection control audits.
• Integrate Infection Control into QAPI: Regularly review infection rates, staff compliance, and vaccine uptake in QAPI meetings.

5. Prepare for Survey Inspections – Mock Survey

• Conduct mock surveys focusing on Infection Prevention, EBP, and COVID-19 Immunization Practice
• Implement corrective actions and re-educate staff based on findings.

Health Equity and QAPI/QAA Improvement

The updated guidance emphasizes the importance of addressing health disparities in long-term care facilities. Facilities must now consider health equity when gathering feedback and analyzing data that may impact health outcomes, such as race, socioeconomic status, and language. This approach will be integrated into investigations of medical errors, adverse events, and resident outcomes. Facilities should also consider factors that affect health equity and outcomes of their resident population when establishing priorities in their QAPI program.

Action Steps

1. Incorporate Health Equity into Data Collection and Analysis

• Track Disparities in Health Outcomes: Collect and analyze data on race, socioeconomic status, language, and other social determinants of health to identify trends.
• Integrate Equity Metrics in QAPI Reviews: Include health disparity indicators when reviewing medical errors, adverse events, and resident outcomes.

2. Enhance Resident and Family Engagement

• Conduct Culturally Responsive Feedback Surveys: Regularly gather input from residents and families in multiple languages to assess their experiences and needs.
• Ensure Accessible Communication: Provide interpreters, translated materials, and alternative communication methods for residents with language or literacy barriers.
• Develop Inclusive Care Plans: Consider cultural, religious, and personal preferences when creating individualized care plans.

3. Strengthen Staff Training and Awareness

• Provide Health Equity Training: Educate staff on implicit bias, cultural competency, and strategies for reducing health disparities.
• Train staff on Language & Communication Barriers: Ensure staff understand how to use interpreters and communicate effectively with residents of diverse backgrounds.

4. Improve Policies and Procedures to Address Disparities

• Establish Health Equity Policies: Develop facility-wide policies that emphasize health equity and nondiscrimination in resident care.
• Address Social and Economic Barriers: Implement strategies to assist residents with transportation, financial, or social support needs that may impact health.

5. Prepare for Survey Inspections – Mock Survey

• Perform mock surveys with an emphasis on health equity and QAPI.
• Implement corrective actions and re-educate staff based on findings.