Long Term Care Braces for QAPI Phases 2 and 3

April 1, 2021
April 1, 2021

The long-term care industry is struggling to deal with a variety of issues. Some such as preventing falls and ensuring emergency preparedness have been concerns for these facilities for quite some time; others such as new regulatory oversight and handling the COVID-19 pandemic are new to the mix. The result is that industry leaders are faced with a multitude of new challenges to manage simultaneously. Needless to say, grappling with the pandemic by itself would be more than all-consuming. When we overlay all of these other elements on top of COVID-19, we find many in this industry overwhelmed by the scope and variety of the issues at hand. This article is Part 2 of our attempt to look more closely at some of the serious concerns of organizations across the continuum of care.

Long-Term Care Faces Even More Requirements with QAPI Phase 2 and Phase 3 Regulations

According to CMS, “QAPI is the coordinated application of two mutually-reinforcing aspects of a quality management system: Quality Assurance (QA) and Performance Improvement (PI). QAPI takes a systematic, comprehensive, and data-driven approach to maintaining and improving safety and quality in nursing homes while involving all nursing home caregivers in practical and creative problem solving” (CMS, 2016). The intention of CMS in establishing QAPI is to ensure long-term care operates using “an ongoing, organized method of doing business to achieve optimum results, involving all levels of an organization” (CMS, 2016). Wide-ranging operational changes include training programs, staffing, reporting incidents, investigation of complaints, medication management, process standardization, etc. This program was set in motion by the Affordable Care Act in 2010 and was to be implemented in three phases completed in 2019. However, the release of Interpretive Guidelines is still pending from CMS for Phase 3. Though this release was scheduled for Q2 2020, it may well be delayed due to the COVID-19 Pandemic.

Skilled Nursing News wrote in November 2019 that “The federal government threw another wrench into the [Requirements of Participation] RoP equation this past summer, when CMS issued a proposed rule that would delay certain aspects of the third round — including aspects of the newly required Quality Assurance Program Improvement (QAPI) plan and certain ethics rules. Providers applauded that decision, but CMS has yet to finalize that proposed rule as of Wednesday afternoon; the final rule is not expected to be published until next year” (Spanko, 2019). Many organizations are worried about the delay and the lack of guidance. The worries of many were shared in a letter written by LeadingAge president and CEO Katie Smith Sloan to CMS administrator Seema Verma. Sloan offered, “This lack of guidance puts nursing homes in an untenable position, as compliance will require lead time for program development, resource allocation, and staff training” (Spanko, 2019). Given the focus across healthcare and especially within long-term care for the COVID-19 pandemic, the QAPI guidelines and the need for organizations to comply with them may be delayed far longer, creating more confusion and anxiety among industry compliance and operation leaders.


CMS, “QAPI Description and Background,” CMS.gov: 9/20/2016, Retrieved at https://www.cms.gov/Medicare/Provider- Enrollment-and-Certification/QAPI/qapidefinition.
Spanko, A., “CMS to Have ‘Limited’ Survey Capacity for New Nursing Home Requirements of Participation,” Skilled Nursing News: November 26, 2019. Retrieved at https://skillednursingnews.com/2019/11/cms-to-have-limited-survey-capacity-for-new-nursing-home-requirements-of-participation/.


This blog post continues a series based on our article, Top Issues Across the Care Continuum - Part Two, which looks more closely at some of the serious concerns of healthcare organizations across the care continuum. An earlier blog post series was based on our article Top Issues Across the Care Continuum – Part One. Subsequent challenges to be examined during this blog post series include:

  • The Abuse Icon on the Nursing Home Compare Website is Problematic for Many Long-Term Care Organizations.
  • Falls with Injury Are a Serious Concern for Long- Term Care Facilities and the People Who Reside in Them.
  • Emergency Preparedness, While Necessary, Is a Burden for Long-Term Care Facilities.
  • Nursing Homes Struggle with the Demands of Required Compliance Surveys and Regulatory Oversight.
  • Changes Related to COVID-19 Will Impact Surveys and Visitation Policies in the Future

There is a long list of challenges for providers across the care continuum, outside of acute care. For example, with consistent wage pressures, shifting compliance regulations, and rising acuity levels among resident populations, the skilled nursing and LTC workforce is feeling more pressure than ever before. HealthStream works with organizations throughout non-acute care to address these challenges, from keeping pace with regulatory requirements to engaging and developing competent staff who can satisfy the demands of increased patient complexity. By partnering with HealthStream, organizations are equipped to seamlessly manage the pressures of surveyor visits, while remaining focused on high-quality patient and resident care. Learn more about HealthStream solutions for non-acute care organizations.

Request Demo