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Even as long-term care providers are busy digesting the 696-page-long advance copy of the Revised Requirements of Participation and Interpretive Guidelines and await the October 2017 additions to the Minimum Data Set 3.0 (MDS), a new laser focus has been trained on the world of restraints and alarms.
With this flurry of activity going on in your mind, do remember that the philosophy of OBRA (the Omnibus Budget Reconciliation Act) has not changed. At the core of OBRA, the overarching mandate continues to be that long-term care facilities must provide care and services such that each resident maintains or attains the highest practicable physical, mental, and psychosocial functioning of which he or she is capable.
Now enter the bits and pieces we have been seeing over the past several months, which will ultimately tie in to the new survey process. Although we are still waiting for the updates to the RAI User’s Manual, we do know that section P of the MDS has been renamed “Restraints and Alarms” and that various personal alarms have been added to item P0200. The coding options are similar to the restraint items in that the assessor must indicate whether the device is 0, Not used; 1, Used less than daily; or 2, Used daily.
In the Fiscal Year (FY) 2018 Skilled Nursing Facility Prospective Payment System (SNF PPS) Final Rule, the Centers for Medicare & Medicaid Services sailed smoothly toward implementation of the Skilled Nursing Facility Value-Based Purchasing (SNF VBP) program, implementing all policies as proposed in the FY 2018 SNF PPS Proposed Rule. The program will launch using the Skilled Nursing Facility 30-Day All-Cause Readmission Measure (SNFRM) (NQF #2510) and will impact Medicare Part A payments in FY 2019 effective Oct. 1, 2018. CMS plans to transition to another measure, the Skilled Nursing Facility 30-Day Potentially Preventable Readmission Measure (SNFPPR), “as soon as practicable.”
CMS anticipates that the first opportunity to replace the SNFRM with the SNFPPR would be the FY 2021 program year. “However, we have not yet determined if it would be practicable to replace the SNFRM at that time,” the agency said. Note: CMS expects to submit the SNFPPR to NQF for endorsement consideration as soon as possible.
“We intend to provide SNFs with SNFPPR rates [in their quarterly reports] prior to the replacement [of the SNFRM] for SNFs to learn more about the measure and incorporate [it] into their quality improvement and care transitions efforts to reduce readmissions. We also intend to further analyze the SNFPPR prior to replacing the SNFRM for any association with social risk factors. …,” said the agency. “We intend to update affected stakeholders on timing in future rulemaking.”
Many providers are still on a learning curve when it comes to accessing, understanding, and using the Review and Correct Reports that the Centers for Medicare & Medicaid Services (CMS) has made available in the Skilled Nursing Facility Quality Reporting Program (SNF QRP). To help SNFs navigate the reports, on Aug. 7 Roberta Constantine, RN, MBA PhD, a senior policy analyst with CMS contractor RTI International, led “SNF Quality Reporting Program: Review & Correct Reports Refresher Webinar.” Note: Access the webinar slides here. Watch for news of a webinar video here.
The Review and Correct Reports are designed to help providers preview and correct their MDS-based SNF QRP quality measures (QMs) for each reporting quarter prior to the QMs being calculated a final time and frozen for the public reporting on Nursing Home Compare that will begin in fall 2018. The following Q&As culled from Constantine’s presentation could help nurse assessment coordinators (NACs) better understand the reporting system:
SUBJECT: October Quarterly Update to 2017 Annual Update of HCPCS Codes Used for Skilled Nursing Facility (SNF) Consolidated Billing (CB) Enforcement
SUMMARY OF CHANGES: This notification provides updates to the lists of Healthcare Common Procedure Coding System (HCPCS) codes that are subject to the consolidated billing provision of the SNF Prospective Payment System (PPS). Changes to CPT/HCPCS codes and Medicare Physician Fee Schedule designations will be used to revise CWF edits to allow MACs to make appropriate payments in accordance with policy for SNF consolidated billing in Chapter 6, section 20.6.
Updated Editing of Always Therapy Services – MCS. Medicare Part B therapy services that are coded as "always therapy" services and the Part B therapy caps.
Two key deadlines for the Skilled Nursing Facility Quality Reporting Program (SNF QRP) are just around the corner, noted officials with the Centers for Medicare & Medicaid Services (CMS) during the Aug. 3, 2017, Skilled Nursing Facility/Long-term Care Open Door Forum (SNF/LTC ODF). Meeting these deadlines—one for reconsideration requests and one for data reporting—is critical for SNFs that want to avoid taking a significant financial hit to their Medicare Part A payments.
“Under the SNF QRP, SNFs that fail to submit the required quality data to CMS for measures that have been finalized for use in the SNF QRP will be subject to a 2 percentage point reduction to the otherwise applicable annual market basket percentage update with respect to that fiscal year,” explained officials.
Here are the two critical SNF QRP deadlines:
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