Part 2: Between the Lines
When the CMPRP Revisions were released in September 2023, they not only provided a defined list of allowable and non-allowable uses of funding and prohibited budget items, but they also made changes to the way CMP applicants were required to APPLY for funding.
HUH?
If you've never applied for CMP funding or if you're not immersed in the in's and out's of the program on a routine basis, that statement probably doesn't make a lot of sense. But if you ARE, you get it. Because there are a lot of "little" things that applicants were previously not required to do (or were required to do) that changed. However, because we were so focused on the bigger changes when the Revisions were unveiled, we missed those changes "between the lines" that are spelled out very clearly in the Memorandum. It's those small things that cause the biggest hiccups in the application and review process. We have also learned some things along the way in the last year of navigating through the new changes. We've asked multiple questions of the CMP National Team and participated in CMS calls. Plus, we have our Regional Office in Atlanta that provides feedback to our questions. So, let's look at a few things we've learned.
Letters of Nursing Home Support for a CMP Project
This one is pretty clear - with its own header - in the new Revisions. Letters of Support are not new to the CMP application. But having a Letter of Support for each participating facility to submit with your application is new. CMS makes it very clear in this section of the Revisions that "if the organization applying for a CMP project is not a nursing home, letters of support from all participating nursing homes are required to be submitted with the application." What that means is that if you are applying for funding to support project implementation in 60 nursing homes, you need LOS for those 60 nursing homes. CMS also adds that they "will not approve projects indicating that the applicant will approach nursing homes to participate in their project after funds are granted." Prior to the Revisions, applicants could submit funding to support project implementation in X number of nursing homes, with a plan to recruit new facilities throughout the project period. This is no longer allowed. You must have facilities that are willing to participate and provide a Letter of Support prior to the submission of your application. A couple of things to note:
Corporate offices can submit ONE letter with multiple nursing homes included
The letter must include at a minimum the project title, time frame (1,2 or 3 years), the faciality's CCN number, and a signature of the individual authorized to commit the nursing home.
Corporate personnel or Administrators should be the only ones providing the LOS.
LOS should be dated less than 6 months from the time of application submission.
Facilities Participating in More Than One CMP-funded Project
This is a hot question! And one that is not found in the new Revisions. Can a nursing home participate in more than one CMP-funded project. YES. As long as those projects do not fall under the same project category. Those categories are clearly outlined in the QSO-23-23-NHs under Allowable Uses of CMP Funding (p. 6-9). How, as an applicant, are you supposed to know what facility is participating in what project and what category that project falls under?!? We are a step ahead of you :) Our website contains a LIST of all of the current projects in NC, what category they fall under, and what facilities are participating in those projects. If you are applying for CMP funding, you are strongly encouraged to check this out!
Program Development and Facility Recruiting
As I stated earlier, recruiting nursing homes to participate in your project during the course of the project is a thing of the past. Your facilities must be committed up front, with signed letters of support that you are able to submit with your application. Additionally, applicants that are offering training cannot use any part of the project period to "develop" the training. Training materials, including PowerPoints, websites, and any additional materials must be completed and submitted with the application for review. You will not be allowed to develop those trainings and materials after the start of the project. CMS intends for funding to be used solely for resident benefit and spending the first 3-6 months of the project developing the program is not considered beneficial to the residents.
Mental Health Training & Workforce Development - NO. Period.
We've had multiple successful projects in the past that fell under these two categories. They had excellent outcomes. We are still shouting their praises. And sadly, when asked if we can approve applications for mental health, behavioral health or workforce development, the answer is NO. But what about... NO. Even if.... NOOOOOO. CMS made it very clear in the Revisions that they would not approve applications for either of these anymore. Why? Because for Mental/Behavioral Health, they are partnering with SAMHSA to launch the Center of Excellence. This will provide support and training to nursing homes to help care for individuals with mental health and substance abuse. Nursing Homes are encouraged to access the program at http://www.nursinghomebehavioralhealth.org/. Dementia training is excluded, and funding will continue to be available. Workforce Development is something that CMS is launching a national campaign to help increase the nursing workforce in nursing homes. For more information, visit https://www.cms.gov/newsroom/fact-sheets/medicare-and-medicaid-programs-minimum-staffing-standards-long-term-care-facilities-and-medicaid.
We love feedback! If there are things that you have learned with the new Revisions or in the application process, please share so that we can too.
Comments