Communication Training: Implementation Deadline

Condensed CMS Policies and Procedures

Communication Training: Implementation Deadline

Jeannine LeCompte, Compliance Research Specialist

Skilled Nursing Facilities must implement an effective communications training program for all direct care staff, as dictated by Section 483.95 (a) of the CMS’s “Requirements for Long-Term Care Facilities,” by November 28, 2019.

According to the Compliance Certification Board’s CHC Candidate’s Handbook, by that date all facilities must have ensured that the following processes are in place and functioning:

– All regulatory guidance material is disseminated.

– All compliance information is communicated throughout the organization.

– Compliance training is taking place.

– All laws and regulations have been distilled into a format that employees can understand.

– All direct care staff are educated on compliance policies.

– A mechanism exists to evaluate employee understanding of compliance responsibilities.

– A “culture of compliance” is promoted throughout the organization.

– Employees are encouraged and able to seek guidance and clarification when in doubt about any issue in this regard.

– All staff are able to participate in continuing education to maintain professional competence.

– Participation in all ongoing compliance training programs is tracked and verified.

– General compliance training is conducted for all employees, physicians, vendors, and other agents.

– Risk-specific training is conducted for targeted employees.

– Human Resources and management are provided with training to recognize compliance risk associated with employee misconduct.

Complying with these prerequisites will require a whole new set of processes and procedures to be put in place, so the earlier facilities start developing them, the better.