Non-Allowable Uses of CMP Reinvestment Funds

• Conflict of Interest Prohibitions:  CMS will not approve projects for which a conflict of interest exists or the appearance of a conflict of interest.
• Duplication: States may not use CMP funds to pay entities to perform functions for which they are already paid by State or Federal sources. 
• Capital Improvements: CMP funds may not be used to pay for capital improvements (a durable upgrade, adaptation, or enhancement of a property that increases its value, often involving a structural change or restoration to a nursing home, or building a nursing home, as the value of such capital improvement accrues to a private party (the owner). 
• Nursing Home Services or Supplies: CMP funds may not be used to pay for nursing home services, or supplies that are already the responsibility of the nursing home, such as laundry, linen, food, heat, staffing costs, medical equipment, resident transportation, resident beds, etc. would duplicate an existing responsibility of the nursing home. 
• Supplementary Funding of Federally Required Services: For example, CMP funds may not be used to recruit or provide Long-Term Care Ombudsman certification training for staff or volunteers or investigate and work to resolve complaints as these are among the responsibilities of Long-Term Care Ombudsman programs under the federal Older Americans Act (OAA), regardless of whether funding is adequate to the purpose.
• Complex Technology: CMP funds cannot be used to purchase high-dollar, complex, or sophisticated technologies, such as telemedicine, alert systems, virtual reality, artificial intelligence, etc.
• Research: Conducting descriptive, analytical, experimental, or integrative research studies on nursing home residents/staff, often consists of projects where the benefit to nursing home residents is unknown or concentrated on the research entity, or a large portion of the budget does not directly benefit nursing home residents. 
• Quality Innovation Network-Quality Improvement Organization (QIN/QIO) Approved Projects: CMP funds cannot be used to fund activities for which QIN-QIOs are already receiving federal funding to complete.
• Charging for Nursing Home Employee Salary: An application to implement a training program to improve staff engagement contained a request for funds to pay the salary of the training coordinator, who was an existing employee of the nursing home applicant.
• Palliative Care Services
• Dental, Vision, and Hearing Services
• Incentives: CMP funds cannot be used for monetary and non-monetary gifts to motivate or encourage individuals to do something, including but not limited to providing monetary incentives for attending trainings or for completing surveys.
• Overlap with State Functions: CMP funds cannot be used to pay for state salaries and for functions that states are required to perform. This category also includes funding for survey and certification operations. 
• Previously Denied CMRP Projects
• Telemedicine Services and Equipment
• Mental and Behavioral Health Support CMP Applications: CMS is committed to improving the quality of care for residents with underlying serious mental illness (SMI) and/or substance use disorder (SUD). CMS has partnered with SAMHSA to launch a national Center of Excellence which provides technical support and training to nursing homes to help care for individuals with SMI and/or SUD. Nursing homes are encouraged to pursue accessing SAMHSA’s training and technical assistance, as CMS will not accept applications for these topics. Dementia training is excluded. To obtain information and access to this program, visit www.nursinghomebehavioralhealth.org. 

More information on who may apply for the use of CMP funds can be found in the frequently asked questions guide below

• FAQ CMP Reinvestment Applications September 2023
• FAQ CMP Reinvestment General Information September 2023