What Implementation of Phase 2 of the Final Rule Will Bring for Rehabilitation Services

Last November, the Centers for Medicare & Medicaid Services put into effect the first phase of a new “mega-rule” update, also known as the Final Rule, to improve long-term care residents’ care and safety.

Many of the changes required in Phase 1 of the Final Rule were minor regulatory modifications. However, Phase 2—which will go into effect on Nov. 28—requires a robust effort to establish facility processes and will be the most taxing phase for many SNF providers.

While some of the most significant aspects of Phase 2 relate to psychotropic medications, a number of other facets will impact virtually all aspects of skilled nursing, including rehabilitation services.

Read on for a look at the upcoming changes as they relate to SNFs and rehabilitation services and the role that person-centered care plays in rehab services.

What the Changes Mean for Rehabilitation Services

The primary focus of Phase 2 will be improving care planning and ensuring quality of care and life by expanding SNF’s responsibilities and strengthening facility requirements.

Three of the most notable changes of this phase include:

  • Baseline care plans will now be due within 48 hours of admission.
  • Annual facility assessments must be conducted and focus on factors like facility processes, staff competencies, and facility resources.
  • Initial QAPI (Quality Assurance and Performance Improvement) plans must be provided to state surveyors during annual surveys.

So what does all this mean for SNFs providing rehab services?

To begin, SNF providers must ensure that staff members are properly trained in caring for long-term care residents—particularly those with dementia—and in preventing abuse. Moreover, staff members must possess the appropriate skill sets and competencies to provide person-centered care to residents.

Second, to improve care planning—including discharge planning—skilled nursing teams must involve residents in all aspects of care planning, beginning at admission. In addition, providers must furnish necessary information for follow-up after discharge and ensure that all instructions are transmitted to residents’ providers and any receiving facilities or services.

Though many facilities already have solid care plan and discharge processes in place, those that don’t will now be required to increase their focus in those areas.

And finally, SNFs must enforce an updated infection prevention and control program, staffed by an infection prevention and control officer. Additionally, SNFs must implement an antibiotic stewardship program that includes antibiotic use protocols and a system to monitor antibiotic use.

The Role of Person-centered Care in Rehabilitation Services

One of the chief goals of the Final Rule is to bolster CMS’ efforts to shift toward person- or resident-centered care. But what exactly is person-centered care, and what role does it play in rehabilitation services?

Person- or resident-centered care is, much like the name indicates, a model of care in which residents play a central, active role in their care and are consulted as decisionmakers. This care model poses a stark contrast to the former, clinician-dependent model that was in place prior to the implementation of the Affordable Care Act.

While the term “person-centered care” was introduced in CMS’ Final Rule, the concept isn’t a new one. In fact, person-centered care already plays a significant role in rehab services.

At Apex Rehab, we’ve long understood the importance of residents’ close participation in their care to achieve successful outcomes. Through our unique clinical programs, we work with facilities’ interdisciplinary teams to deliver resident-focused care in a number of ways, including:

  • Involving residents and their families when establishing a care plan
  • Respecting residents’ rehab goals and wishes
  • Recording residents’ self-reports in clinical documentation

How Apex Rehab Handles Regulation Changes Relating to Rehabilitation Services

At Apex Rehab, we stay on top of regulatory and guideline changes—and help SNFs we partner with navigate those changes.

With Phase 2 of the Final Rule soon to be implemented, the next step for SNFs will be preparing for Phase 3, which goes into effect on Nov. 28, 2019. The key focus of Phase 3 will be completing all remaining requirements, enforcing QAPI obligations, and implementing trauma-informed care.

Apex Rehab partners with Skilled Nursing Facilities to understand and implement regulatory changes like the Final Rule that may affect therapy services. To learn how we can help your SNF, call (412) 963-9698 or fill out this quick form.