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Note that the COVID-19 reporting and SNF QRP reporting changes both will go into effect on May 8 since the effective date is the publication date.
Medicare and Medicaid Programs, Basic Health Program, and Exchanges: Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program
ACTION: Interim final rule with comment period.
Requirement for Facilities to Report Nursing Home Residents and Staff Infections, Potential Infections, and Deaths Related to COVID-19
We are revising § 483.80 to establish explicit reporting requirements for long-term care (LTC) facilities to report information related to COVID-19 cases among facility residents and staff. These reporting requirements are applicable on the effective date of this IFC.
We are revising the compliance date for the SNF QRP to October 1st of the year that is at least two full fiscal years after the end of the PHE. This change is applicable on the effective date of this IFC.
Many directors of nursing services (DNSs) have a hands-off approach when it comes to fee-for-service Medicare Part A and the MDS process, says Suzy Harvey, RN-BC, RAC-CT, managing consultant at BKD in Springfield, MO. “DNSs attend morning meetings and sometimes attend Medicare meetings, but they don’t really get involved because they count on their MDS staff to handle those processes.”
That approach works for the RUG-IV case-mix classification system, but when the Skilled Nursing Facility Prospective Payment System (SNF PPS) switches to the Patient-Driven Payment Model (PDPM) on Oct. 1, rehabilitation therapy will no longer drive Part A skilled care, says Harvey. “With PDPM focused on patient characteristics and skilled nursing services instead of therapy volume, nursing will become key to facility success in this new system, and as the supervisor of the nursing staff, the DNS will need to help lead the way.”
It’s important to note that working on PDPM isn’t just another task to add to the DNS’s plate, adds Harvey. “Getting paid appropriately is the focus of PDPM, but it ties back into quality of care. Much of what you will need to work on for PDPM will also benefit you on survey and your quality measures as well.”
Here are seven key steps a DNS can take to get out in front of PDPM:
On May 4, 2017, the Centers for Medicare & Medicaid Services (CMS) issued an Advance Notice of Proposed Rule-making (ANPRM) to solicit public comments on potentially replacing the existing therapy-driven Resource Utilization Groups, version 4 (RUG-IV) case-mix methodology for the skilled nursing facility prospective payment system (SNF PPS) with a nursing-driven Resident Classification System, version I (RCS-I). The ANPRM set off a firestorm of misinformation about when RCS-I would be implemented and exactly what it would look like, with some industry insiders predicting a finalized RCS-I could implement as early as Oct. 1, 2018 (i.e., for fiscal year 2019).
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.
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.
“Quite a bit” of the regulatory requirements for survey won’t change with the Nov. 28, 2017, rollout of Phase 2 of the Reform of Requirements for Long-term Care Facilities (aka Mega-Rule), say officials with the Division of Nursing Homes in the Survey and Certification Group at the Centers for Medicare & Medicaid Services (CMS) during the video Appendix PP: Overview of Revised Interpretive Guidance.
“Most of the minimum quality standards that were in the regulation remain,” they explain. “There are still strong resident rights, use of the Minimum Data Set to do assessment and care planning based on the residents’ goals and preferences, and the input of the interdisciplinary team. There are still requirements for a medical director, a full-time licensed nurse, and requirements for medication review.”
Nov. 28, 2017, marks the implementation of some significant changes in how the Centers for Medicare & Medicaid Services (CMS) expects nursing homes to operate—and in the survey process that state surveyors will use to assess those operations. CMS survey-and-certification memo S&C: 17-36-NH gives providers critical information about how to prepare for these changes that are required under Phase 2 of the roll-out of the Reform of Requirements for Long-term Care Facilities (aka Mega-Rule) updating the Medicare/Medicaid conditions of participation. This information includes an advance copy of 696 pages of revisions to the F-tags and the Interpretive Guidance in Appendix PP, “Guidance to Surveyors of Long-term Care Facilities,” of the State Operations Manual. Providers should note that the Appendix PP revisions include new subregulatory guidance for multiple F-tags, not just the Phase 2 regulatory changes.
Here’s a summary of critical news—and what’s still to come:
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