Reg's Blog

Senior and Post-Acute Healthcare News and Topics

Presentation Available: New Conditions of Participation for SNFs – Phase 1 Implementation

On the Reports and Other Documents page ( ), I have uploaded a Power Point presentation my firm has made available to clients covering the new Federal Conditions of Participation for SNFs and the implementation elements that are part of Phase 1 (titled “New COPS for SNFs Phase 1”).  The presentation covers what is happening in terms of the new regulations arising out of the law, focused on Phase 1 requirements which began November 28.  The presentation will also alert providers, etc. to Phase 2 issues as applicable.

Additional background information on the Phases and the Rule can be found on this site at these post references:

As always, questions, etc. can be forwarded to me via a comment accompanying this post or via e-mail (contact information on the Author page).  Remember, if you wish a reply/response, please include a valid e-mail address/contact with your post or question.

Happy Holidays!



December 19, 2016 - Posted by | Policy and Politics - Federal, Skilled Nursing | , , , , , , , , , ,


  1. Hi Reg

    Hope all is well and thanks for all your updates. I was wondering if you have seen anything out there related to how skilled facilities should prepare for the 3 midnight rule waiver change coming up Jan1. Specifically how does the skilled facility know the patient was assigned DRG 469/470 in the hospital? Are there specific steps a skilled facility can take to make sure they get paid when only 2 midnight stay in the hospital has occurred?

    Please let me know if you are aware of any specific guidance on this topic, as I am having a difficult time finding a step by step guide to how the skilled facility can be certain it will be reimbursement.


    Ryan Fischer

    Director of Managed Care & Business Development


    [TUTERA senior living & health care]

    Inspired by you

    Comment by Ryan Fischer | December 19, 2016 | Reply

    • Mr. Fischer;

      Check the MLN (Medicare Learning Network)…we should be seeing final guidance pretty soon. Medicare/CMS has said that final guidance will come as the waiver of the 3 day stay is operationalized. Here’s what we do know which is consistent with all other projects of this nature. The identification will be a simple code that reflects the “demonstration project”. I have heard or seen before, a two digit reference – say 75. This code should be used regardless of whether a waiver of the 3 day stay is applicable or not.

      To your other question, the SNF should be able to glean the info. from the hospital paperwork on admission. We have advised clients to use dedicated staff to review prior to admission, the transition and to gather information (paper and other) prior or concurrent to the transfer. I recommend you work with your hospital partners to establish a simple system but typically, you can gather the requisite info. right from the transfer paperwork. If you are looking at taking patient referrals prior to the 3 day stay being met, you definitely want to have systems in-place with the referring hospital, to review care and documentation prior to the transfer. Our clients have produced materials (education), direct call numbers, etc. to provide to hospital case managers to help with this process.

      Hope this helps. Feel free to ask more if necessary. Happy Holidays!


      Comment by Reg Hislop III | December 20, 2016 | Reply

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