Don’t forget F623 pertaining to failure to notify the Ombudsman for facility-initiated transfers/discharges. Within the Interpretive Guidance under F623, CMS defines the notification expectations of providers based on who initiates the transfer or discharge (resident vs. facility). It is key to understand the difference of the two CMS definitions. When this rule first came to light in the new Requirements of Participation, there were a lot of questions about the burden this may potentially place on providers. CMS responded to a few of those questions in a LTC-Survey FAQ document in February 2018. Also, you can find the directive to the surveyors in the CMS Discharge Critical Element Pathway which can be found in the downloads section of the CMS Nursing Home webpage under LTC Survey Pathways.
