A quick reminder that CMS issues a memo on November 22, 2019 with updates on the implementation of Phase 3 ROP requirements, as well as infection control and arbitration agreements. Phase 3 requirements went into effect on November 28th, however CMS acknowledges that it will be very difficult to enforce new requirements without any CMS surveyor guidance. The guidance is not expected until 2nd quarter of 2020. Read the LeadingAge National summary for much more detail.
