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In April 2015, CMS published the ICF/IID Appendix J – Interpretive Guidelines (IGs) to clarify the intent of the Conditions of Participation (CoPs) for ICF/IID and incorporate current standards of practice. This change was the first comprehensive update to the IG in nineteen years. Less than 10% of the interpretation for the regulatory W-tags remained the same. It is critical to update your resource materials to stay current for ICF/IID surveys.

As part of the change, the Compliance Principles, probes and procedures were removed from the IGs and placed into a separate Exhibit (Exhibit 355) behind the IGs. To fully interpret the regulations it is now necessary to refer to two separate sections of the regulations. CMS published a further update on August 14, 2015.

H&W incorporated the Exhibit 355 section with the IGs (including the most recent update) so that the guidance, probes and procedures for each regulation, are now found on a single page.


W194 (4) Staff must be able to demonstrate the skills and techniques necessary to implement the individual program plans for each client for whom they are responsible.

Interpretive Guidelines §483.430(e)(4)

Staff are observed in various settings during the day correctly and consistently implementing the specific IPPs of the clients with whom they are working. EXHIBIT 355: Observation and interview verify whether staff is competent and knowledgeable about the needs, programs, and progress of each sampled client with whom they are assigned to work.

This new resource is now available for purchase and download as a PDF document.

To buy your copy of this highly useful reference guide please visit the H&W Online Store: Click here to go to the H&W online store and this product listing.

This document is available as a single user purchase for $89.00 and in quantity discounts. A five (5) copy bundle is available at a 15% discount for $378. A ten (10) copy bundle is available at 25% off the single copy price for only $668.00.

This is a downloadable product in pdf format. It is an electronic product only. You will NOT receive a printed/hardcopy in the mail. A link to the product download will be included in the invoice you receive via email. Be sure to click on the link and save the file to your computer or server. For multiple copy bundles, you will be able to download the file multiple times. Be careful to change the file name each time or it will overwrite previously downloaded copies.

If you received this notice from a colleague rather than directly from H&W, please email info@hwisolutions.com to add your name to our email announcement list.

Disclaimer: This document and the analysis therein is NOT associated with the Centers for Medicare and Medicaid Services (CMS) in any way. The content is based on the Appendix J and Exhibit 355 to the State Operations Manual (SOM), published April 27, 2015 along with the August 14, 2015 update. For specific guidance, you may want to contact your state survey agency or regional CMS office.

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July 19, 2016

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