CMS has published an Advanced Copy of State Operations Manual Appendix PP to include the revised Requirements of Participation for nursing facilities. Please note before printing that the full document is 821 pages. 

Consistent with CMS’s stated intention to enforce Phase 1 of the new requirements under existing survey guidance and the current F-tags, CMS has inserted the newly effective regulatory language into the sections that represent the closest fit in terms of regulatory intent.

CMS describes its update to Appendix PP, and two other tools it has created, as follows:

This Advanced Copy of Appendix PP must be used for surveys occurring on and after November 28, 2016. CMS will issue a subsequent version of Appendix PP with updated Interpretive Guidance and a re-ordering of F-Tags at a future date. Only Phase 1 regulatory text is effective in this version of Appendix PP. We have included Phase 2 and Phase 3 language, but have distinguished these provisions within Appendix PP and have listed their effective dates.

In addition to the advance copy of Appendix PP, there are two other documents surveyors can use to become familiar with the revisions made to the current F-Tags:

  • Regulation Text by Current Tag Order: This document lists all current F-Tags and corresponding regulation text. New regulation language is identified in red, italicized text. Please note that most F-Tags have new regulatory requirements incorporated.
  • F-Tag Job Aide: This document lists all current F-Tags, their corresponding regulatory section(s) and subparts. The intent of the job aide is to inform surveyors of what has been added into the Automated Survey Processing Environment (ASPEN) system used by surveyors. For example, the advance copy of Appendix PP includes regulation text for Phases 1- 3, whereas ASPEN will include regulation text only for Phase 1.
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Rachel Monger, JD, LACHA is President/CEO. Rachel joined LeadingAge Kansas in 2011 as the Director of Government Affairs and has been a powerful voice for our membership ever since. Rachel is a Kansas licensed attorney and adult care home administrator. She received her bachelor’s degree from Bard College at Simon’s Rock in Great Barrington, MA, and her Juris Doctorate from the University of Kansas School of Law. Over the years, Rachel has served in many volunteer roles in her community and in the state of Kansas to support senior needs, aging services education, and community mental health services. She is also a member of the Board of Governors for the Kansas Health Care Stabilization Fund. As an award-winning trial lawyer, turned award-winning senior care advocate, she has spent nearly two decades passionately supporting quality of care and quality of life for Kansas seniors. When not at work, Rachel loves reading, crafting, volunteering with her church, and spending time with her partner Steven. You can reach Rachel directly at 785.670.8046.