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FGI Position Paper on the Effects of New CMS Rule on Resident Room Layouts


Formal Interpretations

During the end of the development period for the 2018 edition of the Guidelines for Design and Construction of Residential Health, Care, and Support Facilities, the Centers for Medicare & Medicaid Services (CMS) issued its final rule on the “Reform of Requirements for Long-Term Care Facilities.” This updated rule revises the requirements that long-term care facilities must meet to participate in the Medicare and Medicaid reimbursement programs.

Near the end of FGI’s 2018 Guidelines revision cycle, FGI assembled a panel of experts from the 2018 Residential Document Group to ensure alignment of FGI’s minimum requirements with the CMS revisions. Committee members examined the final rule and  potential new risks it might cause for facility operators. Numerous facility design and reimbursement challenges are expected to arise for long-term care facility operators, particularly for existing facilities, because of new requirements in the “Reform of Requirements for Long-Term Care Facilities.”

These reformed requirements now stand as the new reality and may have a significant impact on financial viability for existing long-term facility operators. In response to this concern, FGI reached out to CMS representatives to start a dialogue about facility design issues, particularly  challenges that may emerge as unintended consequences.

This position paper is intended to offer potential solutions and to aid compliance with the CMS reform requirements. The paper can be used to raise awareness, as a basis for dialogue, and as a resource for finding solutions to new challenges related to compliance and the financial viability of facility designs.

FGI intends to continue to seek clarity and continued dialogue with CMS as well as to advance solutions for the success of all parties and, especially, to advocate for the support of uncompromised person-centered care for the recipients of long-term care services.

Guidance For Providers, Designers, And Authorities Having Jurisdiction On CMS Reform Of Requirements For Long-term Care Facilities