With the Centers for Medicare & Medicaid Services (CMS) issuing new updates to surveyor guidance (scheduled to take effect on April 28, 2025), nursing homes across the country are bracing for major changes. These revisions place greater emphasis on the role of medical directors and their ability to implement quality standards, including in diagnosing mental health disorders and prescribing psychotropic medications.
While some may see these updates as a challenge, they also offer nursing home administrators an exciting opportunity to elevate their quality of care, survey readiness, and overall outcomes.
To delve deeper into the updates, their implications for nursing homes, and how Curana Health’s comprehensive medical directorship services can set your facility up for success, read more below:
What is the Focus of the CMS Updates?
The revised surveyor guidance includes two notable updates: one concerning the role of medical directors and the other addressing how mental health diagnoses are documented:
- F841 Update: Expanding the Medical Director Role
Under the updated guidance, medical directors are now responsible for:
- Ensuring all practitioners adhere to facility policies and current professional standards of care.
- Actively participating in Quality Assessment and Assurance (QAA) committees or assigning a designee to do so.
- Guiding the coordination of care policies and addressing concerns identified through quality assurance activities.
- Engaging in facility-wide planning and development of care policies to address patients’ physical, mental, and psychosocial well-being.
- F658 Update: Stricter Guidelines for Mental Health Diagnoses
CMS is increasing oversight to ensure the accurate diagnosis of mental health conditions. Under the updated guidance, medical directors must confirm that all practitioners:
- Use evidence-based diagnostics and criteria in compliance with the latest Diagnostic and Statistical Manual of Mental Disorders (DSM).
- Document comprehensive evaluations, including potential alternative causes for mental health-related symptoms (e.g., substance use or medical illnesses).
- Provide supporting evidence for a mental health diagnosis in the resident’s medical record.
Surveyors will focus on identifying discrepancies through chart reviews and interviews with medical directors and staff. The absence of sufficient documentation or failure to meet these updated standards will cause a facility to be deemed non-compliant.
Why Do These Updates Matter?
This enhanced oversight signals CMS’s intention to improve care quality and reduce inconsistencies in long-term care, with nursing homes experiencing:
- Higher Standards of Care: Meeting these new standards will ensure that patients receive proper evaluations and appropriate interventions for their mental and physical health conditions, leading to enhanced outcomes overall.
- Potential Penalties for Non-Compliance: Facilities who fail to meet the updated guidelines risk citations, financial penalties, and reputational damage.
- Greater Expectations for Medical Directors: With medical directors required to be more hands-on, nursing home administrators must create an environment where these professionals are empowered to take on more responsibilities and oversight.
Looking for Support? Curana Health is Here for You
CMS’s updates offer nursing homes a chance to lead the charge in improving care standards and compliance. While the guidance may seem daunting, success is within reach with the right support system.
At Curana Health, we provide comprehensive medical directorship services designed to not only help nursing homes meet compliance standards, but also thrive under the new CMS updates. Our medical directors:
- Guide training sessions focused on interpreting and implementing new guidelines.
- Provide training in accurate record-keeping for mental health diagnoses and discharge summaries.
- Use technology-enabled electronic health record prompts to support the evaluation of conditions and flagging of incomplete documentation.
- Educate staff on documenting psychotropic medication consents and non-drug interventions.
- Develop safety-first discharge plans that align with compliance regulations.
- Participate in survey interview practice sessions to build confidence under scrutiny.
- Participate in trainings to demonstrate compliance, policy knowledge, and care outcomes with clarity and professionalism.
- Integrate into Quality Assurance and Performance Improvement (QAPI) processes to stay informed of quality metrics (through real-time data) and address key performance issues, such as disparities in care or overprescription of psychotropic medication.
- Work closely with mental health professionals in nursing homes to establish evidence-based practices around psychotropic medication use and align mental health care plans with broader resident care goals.
Set Your Facility Up for Success
Preparing for the updates today will ensure your facility will not just meet the new CMS survey requirements—it will excel. If you’re ready to bring in experienced medical directors, improve compliance, and deliver better outcomes, Curana Health is here to guide you every step of the way.
Reach out to us today to discuss our medical directorship services and other nursing home-specific services.