Mega Rule

On October 4, 2016, the Centers for Medicare and Medicaid Services (CMS) published the final Requirements for Participation in the Federal Register. These Requirements are the final rules that make sweeping changes to the requirements for participation for long-term care facilities (LTCFs). This was the first comprehensive rewrite of the rules for participation in nearly 25 years. In 2015, ASCP submitted comments on the proposed rule focusing on the role of consultant pharmacists in LTCFs. 

In November 2018, CMS released a redline draft of the State Operations Manual. Much of the language is directly from the final Rules for Participation. ASCP previously conducted a webinar on the Rules for Participation, which is available for members to view here. The first document below, ASCP’s Presentation on the Mega Rule, details phase 1 implementation (November 28, 2016) in areas where ASCP commented in our letter to CMS. Also available below is the full redline document (updated language in red, old language in black). In our extensive conversations with CMS, further edits were made for phases 2 and 3.


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