CMPRP Application Handbook.pdf

APPLICATION

H A N D B O O K

CIVIL MONEY PENALTY REINVESTMENT PROGRAM

Volume 1 | November 2025

Introduction The Civil Money Penalty Reinvestment Program (CMPRP) represents a transformative approach to nursing home quality improvement, converting regulatory enforcement actions into meaningful opportunities for enhancing resident care. This innovative initiative from the Centers for Medicare & Medicaid Services (CMS) enables states to strategically reinvest civil money penalty (CMP) funds collected from nursing facilities into projects that directly benefit the quality of life and care of residents.

This resource serves as a comprehensive handbook, providing applicants with a structured framework for developing successful applications. It equips nursing home staff, administrators, and stakeholders with the technical tools and assistance necessary to drive measurable improvements in care delivery. The handbook provides essential guidelines for creating and submitting applications to State Agencies for the strategic use of CMP funds, ensuring alignment with CMS objectives while maximizing benefits for vulnerable nursing home populations nationwide.

The application process for CMP funds is determined by the state in which the nursing home is located. While the handbook guidelines are consistent nationwide, individual states may have different processes, such as submission timeframes and specific procedural steps. Applicants are encouraged to contact their designated State Agency CMPRP representative for more information. See the “State Agency CMPRP Contacts” section for contact details.

Only CMS-approved application forms will be accepted. State Agencies will review applications to ensure compliance with state-specific requirements, program policies, and federal regulations (42 CFR §488.433). For additional assistance or information, the CMS CMPRP Team can be contacted directly at CMP-info@cms.hhs.gov.

Civil Money Penalty Reivenstment Program Application Handbook mailto:CMP-info%40cms.hhs.gov?subject=

Application Handbook | 1

Table of Contents Background

Program Overview

Letters of Support

Project Categories: Allowable Uses of CMP Funds

Non-Allowable Uses of CMP Funds/Budget Items

Technology Projects: Allowable and Non-Allowable Uses

Expansion of Previous CMP-Funded Project(s)

Writing Realistic, Actionable Goals and Quantifiable Objectives

EXAMPLE: CMS CMPRP Proposed Project

Guidelines to Complete an Application

Application Submission and Review Process

Application Budget Spreadsheet

Application Submission Checklist

Project Reporting Requirements

Resources

State Agency CMPRP Contacts

Civil Money Penalty Reivenstment Program

2 | Civil Money Penalty Reinvestment Program Application Handbook | 3

Background A Civil Money Penalty (CMP) is an enforcement remedy that CMS may impose against skilled nursing facilities (SNFs), nursing facilities (NFs), and dually-certified SNFs/NFs when these facilities fail to maintain substantial compliance with Medicare and Medicaid participation requirements for long-term care facilities, as outlined in the Code of Federal Regulations (42 CFR §488.430). A portion of the collected final CMP amount is returned to the state where the facility for which the CMP is imposed is located. The funds must be dedicated exclusively to activities that support and protect nursing home residents.

The legal foundation for the program stems from the federal regulation at 42 CFR 488.433, which provides that CMP funds be utilized specifically to support activities that protect or improve the quality of care or quality of life for long-term care facility residents. The program is funded through the state portion of collected civil money penalties, ensuring a sustainable source of resources for quality improvement initiatives. CMPRP activities encompass comprehensive work related to reviewing applications and State Plans, providing states with the flexibility to address their most pressing nursing home quality challenges. Channeling these resources into evidence-based improvement initiatives, the program creates lasting benefits that extend beyond individual facilities to strengthen the entire long-term care ecosystem.

The program exemplifies CMS’s commitment to opportunities for meaningful quality enhancement, with projects designed to enhance resident safety and well-being, improve clinical care outcomes, strengthen facility operations and compliance, advance industry-wide best practices, support workforce development and training, and promote resident-centered care approaches.

Program Overview Funds are awarded to qualified entities that can effectively implement projects to protect or improve the quality of life and quality of care for residents in federally certified nursing homes.

Project Duration

Eligible Applicants Organization Types Examples

State Agencies, Government Entities State Agency (SA), State/Local/Tribal Governments

Nursing Facilities and Corporations Nursing Facilities, Certified Nursing Facilities, Nursing Facility Corporations

Educational and Research Institutions Academic and Research Institutions

Industry Associations State Healthcare and Provider Association

Consumer Advocacy Organizations and Resident Representatives

Ombudsman, Resident/family councils

Commercial Vendors

Quality-Focused Organizations Quality Innovation Network/Quality Improvement Organizations (QIN/QIO)

IMPORTANT: CMS does not endorse or recommend any vendors or products.

Eligibility Requirements Requirement Category Criteria Detailed Description Qualification and Capability

Must be qualified and capable

Be qualified and capable of conducting the intended project(s) or use(s)

Conflict of Interest No conflict-of-interest relationship

Not have a conflict-of-interest relationship with the entity(ies) who will benefit from the intended project(s) or use(s)

Federal/State Funding Restrictions

No duplicate funding sources

Not be a recipient of a contract, grant, or other payment from Federal or State sources for the same project(s) or use(s)

Service Duplication Prevention

No payment for same function

Not be paid by a state or federal source to perform the same function as the project(s) or use(s)

This structured approach ensures that CMP funds are used effectively to create meaningful improvements in nursing home care while preventing duplication of existing efforts and maintaining program integrity.

IMPORTANT: CMP funds may not be used to enlarge or enhance an existing appropriation or statutory purpose that is substantially the same as the intended project(s) or use(s).

4 | Civil Money Penalty Reinvestment Program Application Handbook | 5

Letters of Support Mandatory Documentation Requirement All project applications must include complete letters of support from participating nursing homes at the time of initial submission. This is a non-negotiable requirement that demonstrates confirmed participation and ensures compliance with CMS funding regulations.

This requirement reflects CMS’s commitment to funding viable, well-planned projects that will deliver measurable improvements to nursing home residents. By requiring confirmed facility participation upfront, CMS ensures that approved projects can be implemented immediately upon funding approval, maximizing the impact of CMP funds on resident care and quality of life.

Corporate/Chain Letter Requirements CMS will accept a letter of support from a nursing home corporation or chain, provided that each participating nursing home facility acknowledges receipt through its Nursing Home Administrator. This includes the administrator’s signature, the current date, and complete contact information (phone number, email address, and facility address). The documentation ensures that each facility within the corporation or chain has agreed to participate and provides direct contact points.

Exception CMS maintains the discretion to grant exceptions in rare circumstances to reduce or eliminate the standard requirement for letters of commitment from participating entities.

These exceptions are considered on a case-by-case basis when the traditional commitment letter process may be impractical or unnecessary for achieving program objectives, such as state-wide nursing home conferences with universal invitations.

Project Commitment

• CMS maintains a strict policy regarding nursing home participation in projects.

• Applications will not be approved if the applicant indicates plans to approach or recruit nursing homes after funding has been granted.

Applicants are required to obtain letters of support from nursing homes, acknowledging each facility’s commitment to implementing projects and that the project funding counts against the facility’s maximum cap per category. Nursing homes are expected to honor their commitment for the entire length of the project. Nursing homes cannot indicate specific years they would like to participate in the project; the applicant must ensure that they are committed to the entire project duration. Therefore, it is important that applicants communicate project information upfront with nursing homes to ensure proper alignment between project scope and facility capabilities. Applicants should clearly communicate the project scope, timelines, resource requirements, and the level of stakeholder involvement.

While circumstances may change during implementation, any withdrawal after a project has been approved compromises the project’s integrity. If nursing homes can no longer participate after approval, applicants have two options:

• Continue the approved project without facility changes, or

• Stop the project entirely and submit a new application with nursing homes that can participate (only applies to projects that have been implemented for six (6) months or less).

NOTE: State Agencies can contact the CMS CMPRP Team when extenuating circumstances exist, such as a nursing home closure. CMS will evaluate on a case-by-case basis.

Requirements Letters of support serve as mandatory documentation that must be:

• Complete and Comprehensive: Clearly outlining the nursing home’s commitment to participate in the proposed project (including project implementation timeframe)

• Properly Authorized: Signed by appropriate facility leadership with authority to commit the organization

• Submitted with Initial Application: Included as part of the original application package, not as supplemental documentation

• Compliance-Focused: Demonstrating understanding of and adherence to CMS funding caps and program requirements

Required Letter of Support: Essential Components Letters are required from ALL nursing homes participating in the project. Each letter of support must include the following elements:

Required Element Description Letterhead Name of facility, address, title, phone number, and email address CMS Certification Number (CCN)

The nursing home’s official CMS certification number

Project Title The exact title of the proposed project Time Frame Complete duration/timeline of the project Budget Cap Acknowledgment

Statement acknowledging that funding counts against the nursing home’s maximum cap /per category

Project Commitment

Statement acknowledging participation for the entire duration, understanding the review process.

Authorized Signature

Must be signed by an individual authorized to commit the nursing home

6 | Civil Money Penalty Reinvestment Program Application Handbook | 7

Example Letter of Support

[Nursing Home Letterhead]

RE: Letter of Support for [PROJECT TITLE]

This letter confirms [Nursing Home Name]’s commitment to participate in the above-referenced Civil Money Penalty Reinvestment Program.

Project Details:

Acknowledgment:

We acknowledge that this funding request will count against our nursing home’s maximum cap for [insert project category] and commit to participating in the project for its entire duration. During this period, we acknowledge that the funding allocation remains in place regardless of organizational changes and other non-extenuating circumstances.

Additionally, we understand the project determination review process may take approximately 90 days, and we will maintain our commitment to this application during the review period.

Authorized Signature:

[Name and Title of Authorized Individual] [Signature] [Date]

8 | Civil Money Penalty Reinvestment Program Application Handbook | 9

Project Categories: Allowable Uses of CMP Funds CMP Funds are available to improve nursing home resident quality of care and life through various categories and project types, each with funding limits and requirements.

Category Purpose Eligible Activities (not all inclusive) Maximum Funding Key Requirements

1. Resident or Family Councils

Support advocacy organizations in developing and strengthening councils

• Assist in the development of new independent family councils;

• Assist resident and family councils in effective advocacy on their family member’s behalf;

• Develop materials and training sessions for resident and family councils on state implementation of new federal or state legislation.

$6,000 per nursing home (one-time funding)

One-time funding

2. Consumer Information

Develop educational materials for residents and families

$6,000 per nursing home (one-time funding)

Materials must directly benefit residents and families in becoming knowledgeable and understanding rights and care processes.

Example: Develop educational materials (e.g., flyers, brochures, booklets, web-based materials, etc.) to promote awareness of the unnecessary use of psychotropic medications, facility requirements, or residents’ rights related to discharge, advance care planning, etc. The goal of these materials is to help consumers understand the risks associated with administering these medications, raise awareness of their rights to consent to treatments, and promote the use of nonpharmacological interventions to improve the quality of life and care for residents diagnosed with dementia.

3. Training to Improve Quality of Care

Provide training in facility improvement initiative in single and multiple nursing homes, joint training of facility staff and surveyors, technical assistance for facilities implementing quality assurance programs, training for resident and/or family councils, LTC ombudsman or advocacy organizations and other activities approved by CMS.

Medical Care: Alzheimer’s, Wound Care, Pain Management, Medication Management, Oral Health Safety & Quality: Patient Safety, Falls Education, Non-Pharmaceutical Solutions Care Approach: Trauma-Centered Care, Person- Centered Care, Cultural Sensitivity, Culture Change

$6,000 per nursing home per year, per topic

$18,000 maximum for 3-year project

multiple topics.*

State Conference A State Agency can provide statewide or regional training to certified nursing homes. States should contact the CMS CMPRP Team at CMS-info@cms.hhs.gov for more information.

*Multiple Training Opportunities for Individual Nursing Homes Nursing homes are eligible to participate in up to three (3) separate training programs over a three (3)-year project duration, with each program focusing on different improvement areas annually. Facilities must remain within established maximum funding limits per topic. For example, a facility might conduct pain management training in year one ($6,000), fall prevention training in year two ($6,000), and dementia care training in year three ($6,000). A total max on $18,000 for a three year project..

Dual Participation Benefits Facilities have the flexibility to attend state-sponsored training programs (i.e., State Conferences) while simultaneously maintaining their eligibility to submit independent funding requests for up to $6,000 in the training category, allowing nursing homes to maximize their educational and improvement opportunities.

4. Activities to Improve Quality of Life

Foster social interaction, movement, and reduce loneliness

Nature-Based: Horticulture/Gardening Therapeutic: Music Therapy, Animal Therapy (including robotic pets) Physical: Tai Chi, movement games, Nintendo Wii Cognitive: Reading/Memory interventions, Crafting

$6,000 per nursing home per year per topic

• Prohibited: complex/high-cost technology (virtual reality, artificial intelligence, or simulation projects)

• Nursing Homes apply for multiple topics separately

10 | Civil Money Penalty Reinvestment Program Application Handbook | 11

Other Project Types Note: State agencies may propose additional project categories for CMS evaluation, provided they align with program goals. CMS has discretionary authority to approve new projects on a limited pilot basis with select facilities or regions to assess effectiveness before considering national implementation.

Category Purpose Eligible Activities (not all inclusive) Maximum Funding Key Requirements

Mental and Behavioral Health

Support behavioral health services that address the needs of nursing home residents.

Examples:

• Training nursing home staff on recognizing and managing behavioral symptoms

• Education on person-centered approaches to dementia care

• Mental health first aid training for facility staff

$6,000 per nursing home per year

Innovative projects that delivery of high-quality behavioral health services

Workforce Enhancement

Designed to support facilities in developing and retaining a qualified, stable workforce through training and education

• Certified Nursing Assistant (CNA) Training program

$6,000 per nursing home per year

The project scope and focus must differ from the Nursing Home Staffing Campaign. Please refer to the webpage and the most recent CMPRP memorandum for more information

Technology Projects

For details on technology projects, refer to the Technology Projects: Allowable vs. Non-Allowable Uses section.

Visit the CMPRP webpage on CMS.gov to view CMP-funded projects, organized by state and calendar year.

https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/civil-money-penalty-reinvestment-program https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/civil-money-penalty-reinvestment-program https://CMS.gov

12 | Civil Money Penalty Reinvestment Program Application Handbook | 13

Examples of Non-Allowable Uses of CMP Funds/Budget Items Please note: The following list is not all-inclusive. Activities beyond those listed require further review.

Category Prohibition Description Examples

Project Material Development of new project curriculum or toolkits.

Funds to create entirely new educational materials, training curricula, or toolkit resources from scratch.

Creating new training manuals from scratch, Developing original educational toolkits, and writing new program curricula.

Conflict of Interest Projects with actual or apparent conflicts of interest

CMS will not approve projects that create conflicts of interest, duplicate existing services, or exceed three years in duration, as CMP funds must directly and solely enhance nursing home residents’ quality of life and care.

Long-term commitments that obligate states to fund large multi-year expenses

Duplication Functions already funded by state/federal sources

States may not use CMP funds to pay entities for functions they already receive payment for from other sources

Enlarging existing appropriations, funding unfunded state legislative directives

Capital Improvements Physical property enhancements that increase value/building modifications

Funds cannot pay for durable upgrades that benefit private property owners, as federal and state payments already acknowledge capital costs

Boiler replacement, nursing home redesign/renovations, landscaping, parking lot construction, concrete patios, any renovations

Permanent fixtures: bathtubs, gardens (permanent and non-mobile), water fountains, installed projection systems, lighting

Nursing Home Services or Supplies

Services/supplies that are facility responsibilities

Cannot pay for items that duplicate existing nursing home responsibilities

Laundry, linen, food/drink, heat, staffing costs, resident transportation (shuttles), Infection Control Supplies: Personal Protective Equipment (PPE)

Medical Equipment: Equipment required for medical services/ procedures, Patient health monitoring equipment, Patient assistive devices (hearing aids, perspection glasses, Resident Assessment Instruments (RAI)

Appliances: Washing machines, Dryers, Microwaves, & Other appliances

Furniture & Comfort: outdoor furniture, resident beds, massage chairs, curtains, air conditioning/heat

Emergency supplies and research equipment

Federally Required Services

Services mandated under federal programs

Cannot fund activities required under programs like the Older Americans Act (OAA) for Long-Term Care Ombudsman programs

Ombudsman certification training, complaint investigation and resolution

Technology Please refer to the Technology Projects: Allowable vs. Non-Allowable Uses section.

Research Studies where resident benefit is unclear

Cannot fund research where benefits are unknown or concentrated on research entities rather than residents

Descriptive, analytical, experimental studies that use large budget portions for development/testing rather than implementation, research or dissemination, conference fees, publication fees)

QIN/QIO Duplicate Projects

Activities already federally funded through QIOs

Cannot fund activities that Quality Innovation Network-Quality Improvement Organizations already receive federal funding to complete

Must check with the State or CMS CMPRP Team regarding active QIN/QIO projects

14 | Civil Money Penalty Reinvestment Program Application Handbook | 15

Category Prohibition Description Examples

Nursing Home Employee Salaries

Paying facility staff wages Cannot pay salaries of nursing home employees Training coordinator salaries, existing employee compensation, employer responsibilities (e.g., background check), and private insurance

Palliative Care Services Billable medical services Cannot fund services that are billable to Medicare, Medicaid, or private insurance

Palliative care services consistent with general medical care

Dental, Vision, and Hearing Services

Services to bridge Medicare coverage gaps

Not intended to cover services Medicare doesn’t provide (some dental training exceptions may apply)

General dental, vision, and hearing services

Incentives Monetary/non-monetary participation rewards

Cannot provide gifts to motivate or encourage participation Payment (e.g., payments or gift cards) for training attendance, survey completion rewards

State Functions Required state responsibilities

Cannot pay for state salaries or required state functions (except administrative use for CMPRP management)

State employee salaries, survey and certification operations

Previously Denied Projects

Resubmission of rejected applications

Cannot reactivate projects that have been denied by CMS Any project previously denied through the CMPRP process

Telemedicine Services and Equipment

Remote healthcare delivery systems

Not appropriate as they often duplicate existing funded services Telemedicine platforms, remote monitoring equipment

Direct Resident Benefit Items unrelated to resident care improvement

Should not include items unrelated to directly improving resident quality of life/care

Should not include items unrelated to directly improving resident quality of life/care

Reserve equipment held in storage, to be used in the future.

Access Fees that are considered enhancements or are not necessary for project implementation.

Travel Costs Travel unrelated to project implementation

Cannot fund travel that does not directly support project implementation.

Travel for nursing home staff, unreasonable mileage and per diem rates, unreasonable commercial airfare rates that exceed category maximums, and any travel expenses that do not use General Services Administration (GSA) rates found on www.gsa.gov.

https://www.gsa.gov.

16 | Civil Money Penalty Reinvestment Program Application Handbook | 17

Technology Projects: Allowable vs. Non-Allowable Uses Technology Project Requirements Primary Purpose: Technology projects must enhance nursing home resident quality of care and quality of life, with residents directly interacting with the technology and documented evidence of measurable improvements in resident outcomes.

Approval Criteria for technology projects ( $6,000 per nursing home per year)

• Direct Resident Interaction requires that residents must actively use or engage with the technology, ensuring that the technology serves those it is intended to benefit rather than just facility operations.

• Measurable Outcomes mandate documented evidence of improvements in resident quality of care or quality of life, providing concrete proof that technology investment produces tangible benefits. CMS reserves the discretion to approve multi-year projects incremental, based on project outcomes.

• Functionality Focus stipulates that only essential components required for technology operation are allowable, preventing unnecessary expenses on features that don’t directly contribute to resident care improvements.

These criteria work together to ensure that CMP-funded technology projects deliver meaningful, measurable benefits to nursing home residents while maintaining fiscal responsibility and program integrity.

Allowable vs. Non-Allowable Technology Uses Category Allowable Uses Non-Allowable Uses Resident Engagement

creates meaningful experiences for older adults by connecting them to the world around them.)

• Entertainment and theater equipment (amplifiers, surround sound system, movie screens, televisions)

can summon help from a pre-programmed list of primary contacts. It can also start up a video call and send text messages. The devices can pick up patterns, learn daily routines, and recall, adding levels of empathy and personalization.

Staff Development

• Technologies primarily for administrative purposes

Educational Resources

• Staff-only educational materials without resident benefit

Care Systems (Artifical Intellegience Technology)

• Telemedicine Equipment/Telehealth Monitoring Devices: Products that monitor patients remotely and alert nursing teams to their outcomes.

monitors to vividly display webpages, videos, directions, restaurant menus, marketing messages, or digital images.)

Upgrades/ Enhancements

• Fees for upgrades, enhancements, etc., that are not required to make the technology function

Examples of Qualifying Technology Projects

18 | Civil Money Penalty Reinvestment Program Application Handbook | 19

Expansion of Previous CMP-Funded Project Applicants who have previously received CMP funding and are submitting a new application with the same project focus for expansion must target a different set of nursing homes.

When submitting an new application for project expansion, the applicant must submit project results that demonstrate successful implementation before duplicating the project in other nursing homes or states. These results must be reported using the CMS-approved criteria and must show measurable connections to resident care outcomes and quality of life improvements. Emphasis should be placed on how the project’s achievements have directly enhanced resident health, safety, and well-being.

For detailed guidance on required reporting criteria, please refer to the “Project Reporting Requirements” section.

NOTE: Previous approval and funding of a project does not guarantee future approval of a similar project. Despite previous approvals, each application receives an independent review based on its merit, content, clear need for the project, and compliance with current CMS CMPRP regulation.

Writing Realistic, Actionable Goals and Quantifiable Objectives Introduction As a component of the application process, it is imperative that applicants state realistic, actionable goals and objectives. Setting realistic, actionable goals and measurable objectives is an effective way to plan the steps needed to make your project achievable. Project goals and objectives must be directly related to the intent of the project and improving the quality of life/care of residents..

What is a goal?

A goal is a desired result you want to achieve and is typically broad and long-term.

• Example: To provide person-centered care to improve the quality of life of residents living with dementia.

What is an objective?

• An objective defines the specific, measurable actions the nursing home must take to achieve the overall goal.

• Typically, one may use the SMART (Specific, Measurable, Achievable, Relevant, Time-Bound) method or a similar method to define and measure specific objectives.

Tips for Writing Smart Objectives

MEASUREABLE Quantifiable to track progress

ACHIEVABLE Realistic and attainable

RELEVANT Relevant and have a rationale

TIME-BOUND Specify a timeframe for completing the objective- by when?

Example SMART X Nursing Home Corporation (WHO) will implement a Dementia Care Training Program for 70 staff in five nursing homes (WHAT) and have 90% of staff participants receive a passing score on the Dementia Care Certification exam (HOW MANY, ATTAINABLE), a nationally recognized person-centered dementia care training certification (PERSON-CENTERED, BEST PRACTICE), by December 31, 20XX (WHEN).

By writing realistic, actionable goals and measurable objectives, you can develop clear applications for review, enable participants to understand the plan’s intent, and increase the potential for your project to be deemed successful.

20 | Civil Money Penalty Reinvestment Program Application Handbook | 21

CMS CMPRP Proposed Project EXAMPLE The EXAMPLE CMS CMPRP Music Therapy Project serves as a comprehensive example of how evidence-based therapeutic interventions can be successfully implemented in long-term care facilities to achieve measurable resident-centered outcomes. It demonstrates how structured music therapy programming can significantly improve quality of life for nursing home residents while meeting CMS person-centered care requirements.

Project Overview Duration: 12 months Focus: Evidence-based music therapy program to improve resident quality of life, reduce behavioral symptoms, and enhance social engagement in long-term care facilities.

Clear Goals & Objectives Framework

Goal Category

Target Method Metric Direct Resident Impact

Emotional Well-being 30% improvement Evidence-based music therapy sessions Geriatric Depression Scale scores Reduced depression, increased happiness Behavioral Management 25% reduction Personalized music interventions Cohen-Mansfield Agitation Inventory Calmer residents, less resistance to care Social Engagement 40% increase Interactive group music programs Activity participation tracking Enhanced social connections, community building Family Satisfaction 35% increase Family involvement in music activities Family satisfaction surveys Stronger family-resident relationships

Core Program Components

Component Frequency Target Population Resident Benefit Individual Music Therapy 2x weekly, 30 min Residents with specific behavioral needs Personalized interventions, targeted care Group Music Activities Daily, 45 min All interested residents Social interaction, community engagement Social interaction, community engagement

3x weekly, 20 min Mobility-limited residents Comfort, emotional support

Memory Care Programming

Daily, 30 min Residents with dementia Cognitive stimulation, memory recall

Achieved Results (Exceeded All Targets)

Outcome Target Achieved Resident Impact Mood Improvement 30% increase 38% increase Significantly reduced depression symptoms Behavioral Incidents 25% reduction 38% reduction Fewer agitation episodes, calmer environment Activity Participation 40% increase 66% increase More residents engaged in community life Family Satisfaction 35% increase 40% increase Stronger family connections and visits

Additional Benefits:

22 | Civil Money Penalty Reinvestment Program Application Handbook | 23

Key Implementation Lessons

Challenge Solution Critical Success Factor Staff skepticism Research education witnessing results Early staff buy-in essential

Diverse preferences Culturally diverse music libraries

Personalization is key

Hearing impairments Vibrotactile instruments visual elements

Adaptive approaches required

Scheduling conflicts Flexible scheduling mobile options

Program flexibility needed

Implementation Essentials

1. Hire qualified music therapist (MT-BC credential required)

2. Conduct comprehensive needs assessment of resident population

3. Secure administrative support for program success and sustainability

4. Develop individualized resident music profiles based on personal history

5. Plan for long-term sustainability from project inception

Why This Example Matters This project statement serves as a model for CMPRP proposals because it demonstrates:

• Clear, measurable objectives with specific targets and metrics

• Resident-centered focus with direct benefits to quality of life

• Evidence-based interventions using validated therapeutic techniques

• Comprehensive implementation strategy with realistic timelines

• Sustainability planning for long-term program continuation

Proven Results The example showcases exceptional outcomes that exceeded all target goals:

• 38% mood improvement (vs. 30% target)

• 38% reduction in behavioral incidents (vs. 25% target)

• 66% increase in activity participation (vs. 40% target)

Guidelines for Completing an Application An effective Application should include the following information. This guide follows the structure of the Application Form.

SECTION I: Applicant Contact and Background Information

• Applicant (individual) Name, Job Title, Email Address

• Organization/Nursing Facility, Organization Type

• Address: Street, City, State, Zip Code

• Website, Organization Status (Profit vs Non-Profit)

• CMS Certification Number(CCN), if applicable

• Phone Number(s)

SECTION II: Organizational Capabilities

Briefly describe your organization’s experience, expertise, and quality improvement work that shows your capacity to execute this proposed project.

This section should demonstrate that your organization has both the operational capacity and subject matter expertise necessary to successfully implement and sustain the proposed project.

SECTION III a: Project Details

• Project Title

• Number of Nursing Homes That Have Committed to Participate

• Project Duration

• Anticipated Start Date (mm-dd-yyyy)

• Anticipated End Date (mm-dd-yyyy

SECTION III b: Previous CMP-Funded Projects

Has this project previously received CMP funding?

If “Yes,” provide the unique identifier(s), dates, and states, as applicable.

Additionally, the applicant must submit project results to demonstrate successful implementation before duplication the project in other nursing homes. These results must be reported using the CMS-approved criteria and must show measurable connections to resident care outcomes and quality of life improvements. Emphasis should be placed on how the project’s achievements have directly enhanced resident health, safety, and well-being.

Refer to the “Project Reporting Requirements” section in the Application Handbook for more information.

IMPORTANT: Applicants who have previously received CMP funding and are submitting a new application with the same project focus for expansion must target a different set of nursing homes.

24 | Civil Money Penalty Reinvestment Program Application Handbook | 25

SECTION IV: Budget

• Total CMP Fund Requested Amount. Provide the amount requested for the entire project. The amount must be the same as the amount reflected in the budget documentation.

Total CMP Funding Requested Amount Annual Amount Requested (as applicable) Year 1 Year 2 Year 3

Cost-Sharing Amount (if applicable) Per Year, Per Nursing Home Amount (as applicable) Year 1 Year 2 Year 3

Complete the CMS-approved Application Budget Spreadsheet. Refer to the Budget Spreadsheet (Excel) instructions on Sheet 1 (tab) and the “Application Budget Spreadsheet” section for guidance on completing it. This budget spreadsheet will reflect a comprehensive, detailed line-item budget outlining specific cost requirements (with justification) within each of the following budget categories (not inclusive): Personnel, Travel, Equipment purchases and rentals, Contractual, Other direct costs, Total indirect costs, and Cost-sharing.

NOTE: If you are requesting funding that exceeds the maximum category funding amount (i.e., the budget cap), please include justification in the budget spreadsheet for consideration.

Justifications may include, but are not limited to, geographic location.

CMS reserves the discretion to approve multi-year projects incremental, based on project outcomes.

SECTION V: Project Category and Summary

• Category: Indicate one category this project should be considered (refer to the “Project Categories: Allowable Uses of CMP Funds section”):

Project Justification: Provide a summary of the Project and its Purpose. Provide specific information regarding the intent and the benefit that implementing this project is expected to have on nursing home residents.

IMPORTANT: Refer to the “Writing Realistic, Actionable Goals and Quantifiable Objectives” section for guidance.

Summary of the Project and its Purpose:

initiative. A goal represents a broad, long-term outcome the project aims to achieve.

o Describe specific, measurable objectives that outline the actions the applicant will take to achieve the stated goal. Each objective should, minimally include the target, method, and metric used to measure success, and demonstrate a direct impact on resident care or quality of life. Objectives must be achievable within the project timeline and aligned with the intended outcomes.

(e.g., training materials, project evaluation report).

o Describe how the project’s performance will be monitored and evaluated throughout its duration, including the specific outcome metrics that will be used to assess progress toward the intended goals. In addition, outline a plan for sustaining the project or its outcomes beyond the conclusion of the project.

Please confirm that the following documents are included with the application submission materials. To ensure your Application meets all requirements for successful submission and review by the State Agency and the CMS CMPRP Team, be sure to reference and complete the “Application Submission Checklist” provided in the handbook. All attachments must be clearly labeled and cross-referenced to the appropriate sections of the application.

Participating Nursing Homes’ Letters of Support

Application Budget Spreadsheet (Excel)

List of Participating Nursing Homes (included in the budget spreadsheet)

Project Results for Previously CMP-Funded Projects (if applicable)

Other Accompanying Documents (if applicable) Please specify the document name, the associated section, and its relevance.

26 | Civil Money Penalty Reinvestment Program Application Handbook | 27

SECTION VI: Supplementary Document Checklist

Name of the Applicant Signature of the Applicant Date of Signature Date the Application was submitted to the State Agency Date of the Application submission to the CMS CMPRP (State Agency Use)

SECTION VII: Submission Confirmation

By signing below, I confirm that this application is accurate and complete and that all required materials have been submitted.

Signature of Applicant (The application must be submitted to the CMS CMPRP Team no later than six (6) months from the date of the submission signature.)

Date of Signature Date Submitted to the respective State Agency

28 | Civil Money Penalty Reinvestment Program Application Handbook | 29

Application Submission and Review Process The CMS CMPRP application review process ensures that all submissions are evaluated equitably, transparently, and objectively, in alignment with established program goals and applicable federal requirements.

Step 1: Application Preparation and Completion Applicants must thoroughly review the CMPRP Application Handbook and use the CMPRP Application Submission Checklist to ensure compliance with the program. The CMS-approved application should be completed with careful attention to all requirements and submitted according to minimum lead times:

• Standard Projects – 90 days before desired start date

• Statewide conference/training – 90 days minimum before desired start date

• Multi-year Projects – 120 days before Year 1 start date

IMPORTANT: The application review timelines may extend beyond the standard 40-60 day framework due to complex corrective actions, additional CMS CMPRP Team questions, high application volumes, technical issues, and coordination requirements between State Agencies and CMS. Applicants should plan for potential extensions, respond promptly to requests, and ensure complete initial submissions using the Application Submission Checklist.

Step 2: Application Submission to State Agency Submit the completed Application Form and all accompanying materials to the State Agency Refer to the Application Checklist for a comprehensive list. Each state manages its own CMP application process with specific timelines and procedural requirements that applicants must follow.

Step 3: State Agency Initial Review The State Agency conducts a comprehensive initial review covering multiple critical areas:

• Compliance with state requirements

• Alignment with CMPRP policies and guidance

• Adherence to Federal Requirements (42 CFR §488.433)

• Evaluation of potential benefits for nursing home residents

Following this review, the state agency will notify the applicant that the application is approved, more information is requested, or the application is denied.

Step 4: State Agency Forwards Application to CMS Once the State Agency determines that the application meets both state and federal requirements, it forwards the completed application to the CMS CMPRP Team via email at CMP-info@cms.hhs.gov.

NOTE: CMS only accepts applications submitted by State Agencies, not directly from applicants.

The official review timeline begins only after the State Agency receives an acknowledgment email from CMS confirming receipt of a complete application.

Step 5: CMS Final Review and Decision The CMS CMPRP Team conducts a further review of all CMPRP requirements. After completing their review, the team will respond with one of two options.

Option 1: No Corrective Actions Needed Decision letter issued to the State Agency within 45 calendar days

Option 2: Corrective Actions Required Applicants are allowed to make up to two attempts to correct identified issues:

• Within 15 calendar days: CMPRP Team contacts the State to request changes to the application, budget, or additional information

• State has 10 calendar days to provide the requested information and submit revisions to CMP-Info@cms.hhs.gov

• Within 60 calendar days: State receives final approval decision from the CMS CMPRP Team

Common Application Issues

Incomplete Documentation: Incomplete application sections

• Missing forms (i.e., budget spreadsheet, letters of recommendation, supporting materials, etc.)

Budget Justification Issues: Inadequate explanation of cost reasonableness

• For project expansions, variations in current and previous budgets (especially funding increases) lack proper justification.

Non-Compliance with Program Requirements: Project activities that don’t align with CMPRP guidelines

• Failure to demonstrate clear benefit to nursing home residents

Scope of Work: Unclear project objectives or outcomes

Step 6: Final Decision Notification CMS makes the final funding determination and issues a formal decision letter to the State CMPRP representative. The state agency then notifies the applicant of CMS’s final decision.

mailto:CMP-info%40cms.hhs.gov?subject= mailto:CMP-Info%40cms.hhs.gov?subject=

30 | Civil Money Penalty Reinvestment Program Application Handbook | 31

Application Budget Spreadsheet Applicants must provide a list of participating nursing homes (facility name, CMS Certification Number (CCN), certified bed count, and a detailed line-item budget using the CMS- Approved Application Budget Spreadsheet (Excel). The budget should outline specific cost requirements with justification within each of the following budget categories. The total budget identified on the spreadsheet must match the amount provided in the Application.

The spreadsheet includes instructions on how to complete it and can be accessed on the CMS CMPRP website.

Personnel

Requirements:

Include employees whose work directly relates to the proposed project

Details to Provide:

Travel

Requirements:

Provide comprehensive breakdown of all travel-related expenses

Components:

Standards:

Must be reasonable rates, preferably aligned with published U.S.

government allowance rates from www.gsa.gov. Rates exceeding GSA standards require justification

Equipment Purchases and Rentals

Requirements:

Materials necessary for project implementation

Details to Include:

Contractual

Requirements:

Costs for sub-contractor or third-party contractor services

Details Required:

Other Direct Costs

Purpose:

Cover expenses not included in previous categories

Requirements:

Must be directly related to project activities

Examples:

Supplies, communications, printing, etc.

Indirect Costs

Definition:

Overhead costs allocable to the project, such as a federal negotiated rate with a university.

Examples:

costs

Requirement:

Submit a copy of federally negotiated rate with a university agreement.

Must not conflict with approved/allowable CMP fund uses

• Must be directly related to project activities

Cost-Sharing

Definition:

Total non-CMP funds received or anticipated for the project (funding sources)

Purpose:

Demonstrates additional financial commitment to the project

IMPORTANT

Exceeding Maximum Funding: If you are requesting funding that exceeds the maximum category funding amount (i.e., the budget cap), please include justification in the budget spreadsheet for consideration. Justifications may include, but are not limited to, geographic location and other relevant factors that support the increased funding request.

Previous CMP Funded Projects: For previously funded projects, applicants must ensure that the budget submitted in the current application is consistent with the previously submitted budget. If there are any variances in line items, particularly increased funding requests, applicants must clearly explain and justify those differences to demonstrate the necessity and appropriateness of the budget changes.

https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/civil-money-penalty-reinvestment-program https://www.gsa.gov

32 | Civil Money Penalty…