The New Rule of participation is not really “new.” Rather, it represents a culmination of society’s growing expectations for eldercare, and the evolving changes in what is known and can be done in settings outside the acute hospital.

While this may seem like a quantum leap from where long term and post-acute care providers are today, the changes have been taking place incrementally for years. What is sudden is that they are now being codified and will be surveyed in a somewhat modified manner come November.

Most of the upcoming regulatory changes have been signaled for years:
  • Think of the growing public and private-sector emphasis on more person-centered care across all of health care.
  • Infection control and antibiotic stewardship are old news that is being repeated due to growing challenges.
  • Patient/resident rights have become central to health care decision making (for example, customer experience emphasis in hospitals, ambulatory care, end-of-life care).
  • Dementia, mental health, and behavioral health care are the focus of collaboratives and pilots as the incidence and awareness of these problems have grown.
  • The higher acuity of the elderly admitted to hospitals, accompanied by earlier discharges from those hospitals, has forced better professional competence all down the post-acute and chronic care continuum, which now receives a greater proportion of the Medicare budget.
  • Quality Assessment Performance Improvement (QAPI) has been an emphasis in all of health care, as well as nursing centers, for years because it makes sense to continuously improve.
With all the specialized capabilities and competencies necessary to treat the population, which may not be the same as every other nursing center, the facility assessment offers a method to help evaluate growing specialization.

Because Quality Indicator Survey states have been exposed to more survey structure, which was also more resident-centric, providers in those states will probably feel a less dramatic change in some ways than in traditional survey states.

Regardless, it can be argued that a provider does not need to know precisely how all the details will play out in the survey process, Medicaid, the Accountable Care Act, arbitration, or bundled payment.

The underlying directive to nursing centers is clear: To operate nursing centers in today’s health care system, it is critical to meet the higher standards for eldercare that are now expected of all health care settings.

The Centers for Medicare & Medicaid Services never sets limits on how good a provider can be, but they do set minimum acceptable standards reflecting the times. That’s what these are—a new normal for all providers in eldercare.

Some may already meet or exceed these standards; others may do it some of the time or in some areas. Some may choose to get out of the business due to the uncertainty of the times, the changes required, or for other reasons. But those who opt to stay in play are being asked to up their game. Everyone. Let’s all look forward to the innovation that emerges as the profession takes on these challenges.

Andy Kramer, MD, is a long term care researcher and professor of medicine who was instrumental in the design and development of the Quality Indicator Survey.