The Centers for Medicare & Medicaid Services (CMS) has unfrozen the Civil Money Penalty (CMP) Reinvestment Program, but the months-long review has led to a few changes. CMS released QSO-23-23-NH on September 25 outlining these changes, including funding caps and an extended list of non-allowable uses of CMP funds.

While some former uses that are now non-allowable have been diverted through other programs, such as workforce through CMS’s new and not-yet-available workforce campaign and behavioral health through the new Center for Excellence in Behavioral Health in Nursing Homes, other projects are simply no longer being funded, such as assistive technologies for telehealth or “complex technology” like virtual reality. In the newly revised CMP Reinvestment Program, projects will be sorted into categories with individual nursing home caps for each category.

Applications that were approved prior to the CMP Reinvestment Program freeze will not be affected by the guidelines released on September 25. Applications that were submitted prior to the freeze with no decision (i.e., the application was neither approved nor denied) can be resubmitted or revised and resubmitted as appropriate.

More information, including FAQs and documents outlining allowable and non-allowable uses, is available on the CMP Reinvestment Program website.