Trauma-Informed Care Toolkit

Regulations

In 2016, the Center for Medicare and Medicaid Services (CMS) issued final regulations for Reform of Requirements for Long-Term Care Facilities. These regulations were phased in over three years. Phase 3 instructed nursing homes to provide trauma-informed services for residents who are trauma survivors. The Phase 3 implementation date was November 28, 2019.

Per CMS, trauma survivors among nursing home residents may include veterans, survivors of large-scale natural and human-caused disasters, Holocaust survivors, and survivors of abuse. The CMS regulations ask nursing facilities to consider the life experiences and preferences of trauma survivors and to address these areas in residents’ care plans. Also, the regulations require that services indicated by the care plan and provided by or arranged by the nursing facility be culturally competent and trauma-informed.

If nursing homes are not compliant with these regulations, there can be serious consequences for the nursing home, staff, and residents. Because the CMS regulations are relatively new and because trauma-informed care is based on a set of principles rather than specific practices, there is an absence of research and best practices, specific to nursing home settings (Kusmaul, 2023). Likewise, every nursing facility community is different, so no two trauma-informed implementation plans will be exactly the same.

Here are several resources to help you better understand the CMS regulations regarding trauma-informed care:

• Fact Sheet: Updated Guidance for Nursing Home Resident Health and Safety (6/29/22)
• Appendix PP: Guidance to Surveyors for Long Term Care Facilities
• Trauma-Informed Care: Nursing Home Requirements and Long-Term Care Ombudsman Program Advocacy

Specific Sections of Guidance to Surveyors Relative Trauma Informed Care

Section	Title	Summary
F656	§483.21(b)(3) Comprehensive Care Plans	Care plans must be culturally competent and trauma informed.
F699	§483.25(m) Trauma-informed care	CMS intention of minimizing triggers and re-traumatizations and implementation date of 11/28/2019.
F726	§483.35(a)(3)(4)(c) Sufficient, competent staff	Nursing staff are sufficient and competent to provide culturally competent, trauma-informed care and services.
F740	§483.40 Behavioral health services	Behavioral health encompasses relative to resident well-being.
F742	§483.40(b), §483.40(b)(1) Treatment and services for residents with a history of trauma	Comprehensive assessment and ensuring residents with trauma history receive appropriate treatment and services.