Phase 3 Requirements of Participation: Admission, Transfer, Discharge; Resident Rights; Food and Nutrition Services; Physician Services

December 9, 2022


Phase 3 of the Requirements of Participation has brought updates to survey regulations and examples. This webinar will focus on updates to resident Admission, Transfer, and Discharges; Residents’ Rights; Food and Nutritional Services; and Physician Services. After a lengthy delay to updating the Requirements of Participation due to the public health emergency, the Phase 3 updates to the RoPs have been released. There have been substantial updates related to Admission, Transfer and Discharge along with important changes related to resident rights. The Food and nutritional Services and Physician services updates are not as substantial but are important. The new guidance, key elements of non-compliance, and examples of deficiencies will be discussed.

Learning Objectives:
1. Identify the facility’s responsibilities when there is a situation where Medicare coverage has ended but the resident continues to need long‐term care services.
2. Give an example that shows how discharges which violate Federal regulations can cause actual and potential harm.
3. Explain how a discharge against medical advice could actually be a facility-initiated discharge.



Carol Maher is a Board Certified Gerontological Registered Nurse with over 30 years of long term care experience and has worked in long term care in many roles. She worked as the MDS Coordinator in a 300 bed SNF in Pennsylvania for 8 years before moving to CA to become the MDS Coordinator/Director for a 1200 bed SNF in San Francisco. She has also worked as the MDS Coordinator in a SNF that typically had 60-75 residents on Medicare in addition to 160 long-term care residents. Most recently she was the Senior VP of Utilization Services and Director of Reimbursement for large multi-facility organizations.

Carol has worked as one of the Gold Standard nurses for MDS 3.0, serving on the RAP workgroup to prepare the way for the CAAs for MDS 3.0, and participating on a number of Technical Expert Panels related to MDS, Quality Measures and care planning. A sought-after speaker, she has given presentations at AANAC, AHCA and Leading Age national conferences as well as many state organization presentations. She is also a frequent author of articles related to the RAI process and PPS. Carol served as a member of the AANAC Board of Directors for 9 years. She is presently serving as the chair of the AANAC Expert Advisory Panel and as an AANAC Master Teacher of the RAC-CT and RAC-CTA certification courses. Ms. Maher is the Director of Education for Hansen Hunter & Co. P.C., providing MDS and Medicare classes across the country, presenting monthly educational webinars and completing compliance audits. She is the author of Long-Term Care MDS Coordinator’s Field Guide (HCPRO 2016).

Credit Hours

  • 1.5 credit hours for RNs
  • 1.5 credit hours for NABs

This pre-recorded webinar expires on November 9, 2024.


Hansen Hunter & Co. P.C. clients are invited to access any of our webinars for free by contacting Allison Johnson at our office at 503.244.2134 to receive your free registration code.


  • This nursing continuing professional development activity was approved by Montana Nurses Association, an accredited approver with distinction by the American Nurses Credentialing Center’s Commission on Accreditation.
  • Enduring material: To meet the requirements for these contact hours, you must watch the entire recorded presentation as well as answer and submit the post-test evaluation that is provided as a link along with the link to your webinar which you will receive via email after completing your purchase.