We know this new rule is daunting for many of our LeadingAge members who provide nursing home services. In order to help you organize your work we have prepared a short summary of the phase I requirements that are due November 28, 2016. We would also remind you that surveyor guidance is not yet published – so even the surveyors are confused by all of this. While the volume of Phase I requirements seems enormous, the vast majority involves clarification of written policies and procedures and inclusion of new definitions. We suggest you go through your own Policy Manuals, section by section, to compare with each of the sections in the new rule and ensure that your policy language is in alignment. There are also identified areas of staff training that must be done and documented, much of which you have likely already been doing. Just make sure you incorporate the new definitions, that you include new areas of resident rights, and that you have the necessary training in abuse, neglect and exploitation; dementia care, and feeding assistance, as outlined by the rule.
