Implementation Issues, Long-Term Care Regulatory Changes: Substandard Quality of Care (SQC) and Clarification of Notice before
Transfer or Discharge Requirements
• New Definition for SQC: A new regulatory definition was published in the Centers for Medicare & Medicaid Services (CMS)
2016 Final Long-term Care Rule and became effective on November 28, 2016.
• Implementing SQC: The new regulatory definition will affect which F-tags and regulatory groupings are considered to be SQC
in both Phase 1 and Phase 2 of the Final Rule implementation process.
• Notice Before Transfer or Discharge Requirements: CMS is also providing clarification in advance of formal interpretive
guidance of 42 CFR §483.15(c)(3)(i) which requires facilities to send a copy of the notice of transfer or discharge to the
Office of the State Long-Term Care Ombudsman.