Phase 3 Regulations went live on 11/28/2019. However, it will be several months before CMS releases any guidance on the new requirements. In a memo released on 11/22, CMS stated:
“While the regulations will be effective, our ability to survey for compliance with these requirements will be limited until the Interpretive Guidance is released.”
Updates and Initiatives to Ensure Safety and Quality in Nursing Homes, 2019-11-22
Phase 3 is a new, complex regulation whose implementation will be more difficult without good guidance. This puts long term care facilities in a challenging position as the regulations must be implemented without clear guidance.
You can find the CMS memo on Phase 3 here: https://www.cms.gov/updates-and-initiatives-ensure-safety-and-quality-nursing-homes