Requirements of Participation: Phase 3 is on the Horizon
Dr. Andy Kramer
By the time this column is published, there will be a little over a year before phase 3 of the Final Rule becomes effective. That day is fast approaching. While studying those regulations, one may try to summarize the main concepts and requirements, and that summary follows. Many organizations have covered most, if not all, of the requirements, while other centers are earlier in implementing programs. And hats off to them. The author of this column hopes that there’s something in the summary that helps most Provider readers and encourages the sharing of program success strategies between centers.
Phase 3 of the new rule touches on multiple issues and care processes, and the regulations require new systems, personnel, and/or training. Prior regulations address many of these same areas, but phase 3 requirements are often more extensive. A major emphasis is training and competency, focusing on specific areas in addition to needs identified in the facility assessment. Nurse assistant training is emphasized, including dementia management, care for residents with cognitive impairments, and abuse prevention.
These four regulatory areas require a program or system with multiple components, often with specific requirements:
A major emphasis is training and competency.
Written policies and procedures must be implemented for maintaining an effective system to obtain and use feedback; collect and use data, including from the facility assessment; monitor performance; and monitor and investigate adverse events.
After taking actions for performance improvement, facilities are expected to measure success and ensure that improvements are sustained. Priorities for performance improvement activities should focus on high-risk, high-volume, or problem-prone areas.
Multifacility organizations have further requirements, including a compliance officer.