Lexology February 25, 2025
Hall Render Killian Heath & Lyman PC

The Centers for Medicare & Medicaid Services (“CMS”) has given surveyors new rules and updates to allow surveyors to assess and cite violations of the regulations on resident discharge and transfer.

On November 18, 2024, the Quality, Safety & Oversight Group at CMS issued a memorandum entitled “REVISED: Revised Long-Term Care (LTC) Surveyor Guidance: Significant revisions to enhance quality and oversight of the LTC survey process” (“New Surveyor Guidance Memo”).

The New Surveyor Guidance Memo consolidates existing F-Tags, enhances surveyor oversight and reinforces protections against inappropriate discharges.

Key Changes to Discharge and Transfer Surveyor Guidance

Consolidation of F-Tags

CMS has streamlined the existing framework by eliminating:

  • F-Tag 622 Transfer and Discharge Requirements (cited 379 times in 2024)
  • F-Tag 623...

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