On November 22, 2019, CMS issued a memorandum with an update on the Phase 3 Requirements of Participation. In this memo, CMS advised:
- CMS will not release updated Interpretive Guidance and training addressing Phase 3 until the second quarter of 2020. CMS is somewhat limited in its ability to survey until then.
- But... nursing homes are still expected to comply with Phase 3 by November 28, 2019.
What does this mean??
It means that, right now, nursing homes are required by law to comply with Phase 3, including the Compliance and Ethics Program requirements - and CMS expects nursing homes to be in compliance.