The CMS’ State Operations Manual appears updated—but not by much

After years of changing and adding new Conditions of Participation (CoP), CMS has finally updated its only guidance for surveyors, State Operations Manual, Appendix A (SOM). But not entirely.

The online document—which is always saved under the same link, year after year— was last fully updated in February 2020, although even then several sections were marked “guidance is pending and will be updated in future release.”

Most, if not all, of those sections are not updated in this version, which is now dated July 21, 2023.

CMS' practice is to mark revisions each time in red. In this version, the date is in red as are changes under A-0144, which outlines updated guidance for the CoP guaranteeing “the patient has the right to receive care in a safe setting.” The changes were summarized CMS transmittal 216, also released on July 21.

It also appears that footnotes under A-0154, which discusses restraint and seclusion requirements, have also been updated.

Often referred to as just SOMA, the appendix offers interpretive guidelines for CMS’ own state surveyors, and in general has been held as the guide for all the accrediting organizations (AO) as well.

Over the past few months, CMS has issued several updates to the online interpretive guidelines for other providers.