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Tomorrow (November 28) is the implementation date for Phase 2 of the new RoPs.

ROLF has created a compliance packet to help SNFs implement these changes. For information on what is included in our Phase 2 packet and how to order, please see our Original Post.

Also, note that CMS issued a Survey & Certification Memo on Friday, November 24, 2017, which adopted a temporary moratorium for SOME of the Phase 2 requirements. (To access the memo, click here).

CMS will provide an 18-month moratorium on the imposition of certain enforcement remedies for the following list of F-Tags:

  • F655 (Baseline Care Plan)
  • F740 (Behavioral Health Services)
  • F741 (Sufficient/Competent Direct Care/Access Staff-Behavioral Health)
  • F758 (Psychotropic Medications) related to PRN Limitations
  • F838 (Facility Assessment)
  • F881 (Antibiotic Stewardship Program)
  • F865 (QAPI Program and Plan)
  • F926 (Smoking Policies)