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Historically, many providers have treated the MDS and the Resident Assessment Instrument (RAI) process as a silo of government-mandated busywork. That’s always been a problem because, since day 1, the primary purpose of the MDS has been to identify resident care problems that are addressed in an individualized care plan. However, the footprints of the MDS are now carved deep into multiple facets of facility life, including:
· The Medicare Part A Skilled Nursing Facility Prospective Payment System (SNF PPS);
· Some Medicare Advantage payment systems;
· Some Medicaid payment systems;
· The MDS-based quality measures (QMs) that are publicly reported on Nursing Home Compare and used in the Five Star Quality Rating System; and
· The MDS-based QMs that will be publicly reported under the Skilled Nursing Facility Quality Reporting Program (SNF QRP) beginning in October 2018 assuming ongoing data issues are resolved timely. Note: SNFs also must meet an MDS-based reporting threshold under the SNF QRP to avoid a SNF PPS payment penalty each fiscal year.
Last but not least, the new Long-term Care Survey Process (LTCSP) makes sure that surveyors have MDS-based clinical indicators to guide their investigations from the moment they walk in the door, according to the LTCSP Procedure Guide.
Slides, audio recording, and transcript from the Dec. 11, 2017, CMS webinar on the MDS-based quality measure (QM) reports in the Skilled Nursing Facility Quality Reporting Program.
As early as spring 2018, the Centers for Medicare & Medicaid Services (CMS) intends to replace the current staffing measures posted on Nursing Home Compare and used in the Five Star Quality Rating System that are calculated from information submitted on the CMS-671 form, said agency officials during the Nov. 2 Skilled Nursing Facility/Long-term Care Open Door Forum (SNF/LTC ODF). The new staffing measures currently under development monitor, for example, the level of hours per resident per day, as well as rates of turnover and tenure. These new staffing measures will be calculated using Payroll-Based Journal (PBJ) data—with an assist on census from the MDS.
While CMS isn’t ready to release details like the applicable data collection timeframes or the technical specifications of the new measures, one point is clear: Timely submission of both PBJ staffing data and the MDS assessments/records that drive census is paramount.
We recently notified Skilled Nursing Facility (SNF) providers that all data for assessment-based measures required for the SNF Quality Reporting Program (QRP) in CY2017 would remain open to modifications until May 15, 2018, and that you would be notified when the Q1 2017 data that was “frozen” as of August 15, 2017 would be open and subject to updates again.
Please be advised that the submission deadline for Q3 2017 data has been modified to May 15, 2018. The SNF Review and Correct Report has been updated to reflect that both Q1 and Q2 2017 are “Open”. Data for all measures for Q1 2017 have been recalculated for any assessment records that have been received since the original Q1 2017 submission deadline of August 15, 2017.
The SNF Review and Correct report is available in the SNF Quality Reporting Program report category in the CASPER Reporting application. Providers are encouraged to request the report to view updated measure results. The updated report should replace versions of the report previously requested.
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