Laguna Honda revises skilled nursing policies under new CMS Phase 3 guidelines

The City of San Francisco held a government meeting on July 4, 2025, focusing on significant updates to policies regarding resident care in skilled nursing facilities, particularly in light of new guidelines from the Centers for Medicare & Medicaid Services (CMS). The meeting addressed various agenda items, primarily centered on the implications of the recently published Phase 3 guidelines.

The first major topic discussed was the expanded definition of resident restraints. The new CMS guidelines broaden the scope of what constitutes a restraint, including devices like bed alarms and chair alarms that limit a resident's independent movement. This necessitated revisions to existing policies at Laguna Honda, with an emphasis on reducing the use of restraints while ensuring resident safety. The challenge lies in balancing the need for safety against the goal of fostering independence among residents.

Another key discussion point revolved around admissions policies for individuals with behavioral health issues. The new regulations prohibit discrimination against individuals with mental health and substance use disorders during admissions and discharges. However, they also require skilled nursing facilities to provide appropriate mental health services. This dual obligation presents a complex challenge for facilities, as they must ensure both individual rights and the safety of all residents.

The meeting also highlighted the extensive volume of policy revisions required to comply with the new CMS Phase 3 requirements, with approximately 44% of the policies under review directly related to these changes. The sources for these policy updates included the California Department of Public Health and various skilled nursing professional associations, ensuring that the revisions align with regulatory standards.

Training and communication were also addressed, with a focus on how staff are informed about policies. The Laguna Honda intranet serves as a resource for staff to access policy information, and all employees, including temporary staff, undergo training on these policies during their onboarding process. Additionally, cultural competence and trauma-informed care training are mandatory for all staff members, reinforcing the facility's commitment to comprehensive resident care.

The meeting concluded with discussions on effective communication strategies for residents with hearing impairments, ensuring that appropriate sign language assistance is available. Overall, the meeting underscored the ongoing efforts of the City of San Francisco to enhance resident care in skilled nursing facilities while navigating the complexities of new regulatory requirements.