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New SNF Conditions of Participation: Implementation Timeframes

About ten days ago, I published a post regarding the new Federal Conditions of Participation for SNFs.  This long awaited regulatory update includes new, revised, and existing regulations published in final rule form last week (October 4).  The post is here for reference http://wp.me/ptUlY-kL

The questions frequently asked regarding the new CoPs (since release) are around implementation dates.  As readers will note, whether in my post or in the actual Final Rule, enforcement is in phases spanning a three year time frame – November 2016 through 2018. Recall that the CoPs in the Final Rule are the broad law changes.  Implementation requires specificity found (typically) in the Interpretive Guidelines – the actual “regs”.  We aren’t there yet and given the breadth of change in certain instances, time is necessary for regulations to be written and providers to comply.  Hence, the phasing.

I have posted below, the implementation timeframe for reference.  This guide is available via this post and is hosted on the Reports and Other Documents page on this site. I have articles forthcoming (soon) here and on other sites regarding implementation strategies and tips.  In the meantime, readers can always forward a question via comment to this post or to my e-mail address noted on the Author page.  Remember: If you want an answer direct, please provide a current, working e-mail address.  I do respond to all questions and comments as efficiently as I can.

The timeframe document is here:

implementation-timeframes

 

October 11, 2016 Posted by | Policy and Politics - Federal, Skilled Nursing | , , , , , , , , | Leave a comment