Navigating Updated CMS Surveyor Guidance: What Long-Term Care Providers Should Expect in 2025

On November 18, 2024, the Centers for Medicare & Medicaid Services (CMS) issued a memorandum outlining significant revisions to the Long-Term Care (LTC) Surveyor Guidance. These changes, effective February 24, 2025, aim to enhance the quality and oversight of the LTC survey process, ensuring better outcomes for residents and improved compliance for providers.

Let’s take a look at what LTC providers can expect in the coming months regarding these changes.

Key Updates to Survey Guidelines

Admission, Transfer, and Discharge

CMS has introduced F-tags F627 and F628 to streamline guidance on admission, transfer, and discharge processes, replacing older F-tags F622–F626 and F660–F661. This change prioritizes resident-centered transitions, emphasizing:

• Clear Admission Policies: Facilities must ensure that admission policies are not only clearly defined but also communicated effectively to residents and families. This includes criteria for accepting residents and addressing their unique needs.
• Transfer Coordination: Transitions between care settings (e.g., hospital to LTC facility or facility to home) must be seamless. The guidance encourages enhanced communication and documentation to prevent lapses in care during transfers.
• Discharge Planning: A greater focus is placed on comprehensive discharge planning, requiring facilities to involve residents and their representatives in the planning process, provide clear instructions for post-discharge care, and ensure follow-up to reduce the risk of rehospitalization or adverse outcomes.

Chemical Restraints and Psychotropic Medications

Guidance on chemical restraints and psychotropic medications has been consolidated under F605, reflecting a commitment to resident rights and ethical medication practices. Key changes include:

• Restricting Chemical Restraints: Facilities are now explicitly required to avoid the use of medications as a form of control or convenience, except in cases where clinically necessary.
• Documentation and Justification: The use of psychotropic medications must be thoroughly documented and justified in the resident’s care plan. Providers must outline why the medication is necessary, the expected outcomes, and ongoing evaluation plans.
• Behavioral Interventions First: Facilities are encouraged to use non-pharmacological interventions to address behavioral symptoms before turning to psychotropic medications. Examples include environmental modifications, structured activities, and therapeutic engagement.

Resident Assessment

CMS has emphasized the accuracy and thoroughness of Minimum Data Set (MDS) assessments, which serve as the foundation for care planning. Key updates include:

• Increased Accountability: Facilities must demonstrate that MDS assessments accurately reflect residents’ conditions, including physical, cognitive, and psychosocial needs.
• Improved Coordination: The guidance calls for better collaboration among interdisciplinary teams to ensure assessments are complete and address all aspects of resident care.
• Enhanced Training: Staff involved in MDS assessments are expected to undergo specialized training to improve their ability to document and interpret data accurately.

Quality of Life and Quality of Care

Enhancements in this area underscore the importance of prioritizing residents’ overall well-being. Changes include:

• Person-Centered Practices: Facilities are encouraged to incorporate residents’ preferences and cultural considerations into care plans to promote autonomy and dignity.
• Environment and Activities: The guidance emphasizes creating a supportive environment that fosters independence, provides meaningful activities, and reduces feelings of isolation or boredom.
• Pain and Symptom Management: A renewed focus on addressing physical discomfort and managing chronic conditions holistically is a cornerstone of these updates.

Administration and QAPI Programs

CMS has bolstered expectations for Quality Assurance and Performance Improvement (QAPI) programs, urging providers to focus on continuous improvement. The key enhancements include:

• Data-Driven Decisions: Facilities must utilize data to identify areas for improvement, track progress, and measure the effectiveness of interventions.
• Resident and Family Feedback: Input from residents and families is now a critical component of QAPI processes, ensuring that improvement efforts are relevant and meaningful.
• Proactive Risk Management: The guidance encourages facilities to identify and mitigate risks before they result in adverse events, such as falls, infections, or medication errors.

Infection Prevention and Control

The revised guidance builds on lessons learned during the COVID-19 pandemic, introducing updates that include:

• Expanded Immunization Requirements: Facilities must ensure that residents and staff are vaccinated against communicable diseases, including COVID-19, per current public health recommendations.
• Enhanced Surveillance Systems: Facilities are expected to implement robust infection tracking systems to identify and respond to outbreaks swiftly.
• Training and Resources: Infection Preventionists must receive ongoing training, and facilities should provide resources to staff to stay informed about evolving best practices.

What LTC Providers Can Do To Prepare

As February 24, 2025, approaches, LTC providers will need to navigate a period of preparation and adjustment to align with the updated CMS guidelines. This transition offers an opportunity to refine processes, enhance care delivery, and ensure compliance with new standards. Here’s what to anticipate in the coming months and how to prepare effectively.

Training & Education

Training and education will be a critical first step. CMS will provide resources through the Quality, Safety & Education Portal (QSEP), offering targeted training modules that address the nuances of the updated guidelines. However, facilities must go beyond these external resources by developing internal training programs tailored to their unique operations. This could include workshops, team-specific sessions, and real-world application scenarios to ensure staff are fully equipped to implement the changes.

Policy & Procedure Updates

Policy and procedure updates will also take center stage. Providers will need to review and revise existing protocols, especially those related to admissions, discharges, medication use, and infection control. For instance, discharge planning must now prioritize greater resident and family involvement, while policies around medication management must align with stricter requirements to justify psychotropic drug use and avoid unnecessary chemical restraints. Simultaneously, documentation practices will need improvement to meet the enhanced standards. Comprehensive and accurate records will be crucial in demonstrating compliance during future surveys.

QAPI Programs

Another essential focus will be strengthening Quality Assurance and Performance Improvement (QAPI) programs. The new guidelines call for a proactive, data-driven approach to quality improvement. Facilities should assess current QAPI processes, identify areas of vulnerability, and implement initiatives that address recurring issues such as falls, infections, or medication errors. Including residents and families in these discussions can offer valuable perspectives and ensure that improvement efforts align with their expectations.

Invention Prevention & Control Protocols

Infection prevention and control protocols will require significant attention, reflecting the heightened importance placed on resident and staff safety. Updated requirements include expanded immunization protocols, enhanced infection tracking systems, and better outbreak preparedness. Facilities must invest in training for staff and designate a dedicated Infection Preventionist to lead these efforts.

Survey Prep

Finally, providers should prepare for CMS surveys, which will begin using the revised guidance in February 2025. Conducting mock surveys can help facilities identify and address compliance gaps in advance. These practice assessments, coupled with continuous monitoring systems, will ensure that providers are not only ready for official inspections but also maintain ongoing compliance in their daily operations.

The months ahead offer a chance for LTC providers to enhance care practices, refine internal systems, and build resilience in an evolving regulatory environment. With thoughtful preparation, facilities can meet the new standards while continuing to prioritize the health and well-being of their residents.

What to Expect After February 24, 2025

Once the revised guidance takes effect, CMS surveyors will use the updated criteria during inspections. Providers should expect a sharper focus on compliance with new F-tags and greater scrutiny in areas like resident assessments, infection control, and QAPI programs.

Survey findings will likely prioritize resident-centered care, safety, and adherence to updated regulations. Non-compliance could result in deficiencies or penalties, making preparation essential for all LTC organizations.

How Showd.me Can Help

At Showd.me, we understand the complexities of navigating regulatory changes. Here’s how we can support LTC providers:

• Customized Training: Our platform offers tailored training programs to align with the latest CMS guidelines, ensuring your staff is well-prepared.
• Compliance Tools: With Showd.me’s robust tracking and reporting tools, you can monitor staff training progress and compliance readiness.
• Resource Updates: We stay ahead of regulatory changes, delivering up-to-date materials and resources that help your team maintain compliance effortlessly.

---

The revised CMS guidance represents an opportunity to enhance the quality of care and compliance standards across LTC facilities. By preparing now, providers can ensure a smooth transition and continue delivering exceptional care to residents.

For more information on how Showd.me can support your organization, visit us at www.showd.me.