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

 This article is Part 1 in a 4-part series to explain the CMS changes for LTC facilities and actionable steps for compliance. This article focuses on Resident Rights and Quality of Life and Admission, Transfer, and Discharge Policies. 

CMS regularly updates guidance to address emerging trends in deficiency citations across the nation, focusing on enhancing resident health, safety, and quality of care. These updates offer nursing homes an opportunity to improve their practices and align with evolving standards of care. On November 18, 2024, the Centers for Medicare & Medicaid Services (CMS) released the memo, “Revisions to the Long-Term Care (LTC) Surveyor Guidance Process: Significant revisions to enhance quality and oversight of the LTC survey process“. However, on January 15, 2025, CMS released revisions adding Nursing Services, Payroll Based Journal. CMS stated the effective date of March 24, 2025, will allow ample time for surveyors and nursing home providers to provide training and education on this new information. In the January 15th memo, QSO-25-12-NH, CMS announced that these updates will be included in Appendix PP of the State Operations Manual (SOM). 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.

Focus on Resident Rights and Quality of Life

All residents are entitled to rights protected by federal and state laws and regulations, including the fundamental right to be treated with dignity and respect. CMS is dedicated to continuously improving the effectiveness and efficiency of its oversight of nursing homes. Their commitment to safeguard the health and safety of nursing home residents is evident by a data-driven approach, which helps identify areas for improvement and clarify guidance. By implementing targeted solutions and updates, CMS aims to enhance the quality of care provided by nursing facilities.

Action Steps

1. Educate and Train Staff

• Educate and train staff on resident rights state and federal regulations. Education and training should be ongoing.
• Provide specific examples and role play scenarios in staff meetings of how to honor and respect dignity in daily interactions. 

2. Evaluate Facility Policies and Procedures

• Review policies to ensure alignment with updated CMS guidance on resident rights.
• Address gaps or inconsistencies that might compromise residents’ dignity or quality of life.

3. Encourage Open, Accessible and Regular Feedback from Residents, Families, and Staff

• Create communication channels such as resident council meetings, and anonymous surveys for residents, families and staff.
• Administrator/DON should maintain an open-door policy and ensure a visible presence in resident care areas during peak visitor hours.
• Respond promptly to concerning feedback to demonstrate commitment to improvement.

4. Foster a Culture of Respect and Dignity

• Train staff to personalize care, acknowledging individual preferences, and cultural values.
• Reinforce and practice communication skills to promote empathy and understanding.

5. Enhance Resident Quality of Life through Meaningful Activities

• Offer a diverse array of recreational and social activities tailored to the residents’ interests and abilities.
• Encourage resident participation in planning these activities to ensure they align with their preferences.

6. Prepare for Survey Inspections – Mock Surveys with External Evaluators to Gain Fresh Perspectives

• Conduct mock surveys focusing on transfer and discharge policies to identify potential issues before inspections.
• Implement corrective actions and re-educate staff based on findings.

Admission, Transfer, and Discharge Policies

Facilities are now prohibited from including language in admission agreements that request or require a third-party guarantee of payment, addressing concerns about financial coercion. Additionally, several outdated tags related to transfers and discharges have been removed to streamline the survey process. Tags F622-F626, and F660-F661 will be deleted, and new tags, F627: Inappropriate Transfers and Discharges and F628: Transfer and Discharge Process, have been established. By understanding these updates, nursing homes can refine processes to better support residents during transitions of care.

Action Steps

1. Review and Update Admission Agreements

• Remove any language that requires a third-party guarantee of payment.
• Ensure agreements align with the new regulations to prevent financial coercion concerns.

2. Educate Staff on Regulatory Changes

• Provide training to admissions, billing, and management staff about the prohibition of third-party guarantees.
• Highlight the new tags, F627 and F628, to ensure understanding and compliance with the updated transfer and discharge processes.

3. Audit Existing Admission Agreement Documents

• Conduct a review of current and past agreements to identify and correct non-compliant language.
• Notify affected residents or families of changes if needed.

4. Streamline Transfer and Discharge Processes

• Develop or update policies to align with the requirements under F627 and F628.
• Ensure staff understand how to handle transfers and discharges appropriately, minimizing risks of non-compliance.

5. Implement Monitoring Systems

• Establish a system to regularly review transfer and discharge decisions for compliance with F627 and F628.
• Use QAPI programs to identify trends or issues related to resident transitions.

6. Communicate Updates

• Inform residents, families, and staff about changes to admission agreements and discharge processes.
• Provide clear explanations to alleviate concerns and demonstrate commitment to compliance.

7. Prepare for Survey Inspections – Mock Survey

• Conduct mock surveys focusing on transfer and discharge policies to identify potential issues before inspections.
• Implement corrective actions and re-educate staff based on findings.