On Oct. 3, CMS published a correction notice for the Fiscal Year (FY) 2019 Skilled Nursing Facility Prospective Payment System (SNF PPS) final rule to address a series of technical errors. “Chief among those” were corrections to the total case-mix-adjusted federal per-diem RUG-IV payment rates that were necessary due to errors in copying values, said officials with the Centers for Medicare & Medicaid Services (CMS) at the Oct. 11 Skilled Nursing Facility/Long-term Care Open Door Forum (ODF).
Specifically, CMS has issued updated versions of both Table 6, “RUG-IV Case-Mix Adjusted Federal Rates and Associated Indexes—Urban,” and Table 7, “RUG-IV Case-Mix Adjusted Federal Rates and Associated Indexes—Rural,” to correct the Total Rate column. For example, those tables in the FY 2019 SNF PPS final rule show federal RUX payment as $832.89 for urban SNFs and $852.10 for rural SNFs. The correction notice changes the federal RUX rate to $832.61 urban and $851.84 rural.
Other FY 2019-specific corrections include the following:
· Updates to the FY 2019 SNF PPS wage index files. In addition to making errors copying values, CMS inadvertently included a critical-access hospital in the wage data, as well as including errors in the wage data collected from the Medicare cost reports of one hospital, said officials. Note: The FY 2019 SNF wage index derives from hospital inpatient PPS (IPPS) wage data, exclusive of the occupational mix adjustment, from FY 2015 cost reports. “The website has been updated to reflect all of these changes to the SNF wage index,” they added.
· Mislabeled FY 2019 SNF PPS impact discussions. In Table 45, “Impact to the SNF PPS for FY 2019,” of the FY 2019 SNF PPS final rule, CMS misordered the ownership labels as “Government,” “Profit,” and “Non-Profit.” The correction notice puts them in the correct order of “Profit,” “Non-Profit,” and “Government.” In addition, CMS mistakenly said that “providers in the urban rural West South Central region will experience the largest estimated increase in payments of approximately 3.5 percent.” The correction notice updates the region to be “rural West South Central,” said officials.
“As discussed in the FY 2019 SNF PPS correction notice, these changes are effective as if they were included in the FY 2019 SNF PPS final rule, meaning that they are effective as of Oct. 1, 2018,” said officials. “All related CMS products, such as our Pricer, have been updated to reflect these latest values.”
Other ODF highlights include the following:
PDPM correction too
The CMS correction notice also includes one correction that was specific to non-therapy ancillary (NTA) classification under the Patient-Driven Payment Model (PDPM), said officials. In the FY 2019 SNF PPS final rule, column 2 of Table 27, “Conditions and Extensive Services Used for NTA Classification,” cites the data source of each condition/extensive service. The final rule erroneously listed the data source for “Highest Stage of Unhealed Pressure Ulcer—Stage 4” as MDS item M0300X1. The correction notice changes that to MDS item M0300D1.
CMS plans new PDPM website
“We understand and appreciate the need for additional educational and training materials related to PDPM, and we have dedicated significant resources to developing and disseminating these materials as quickly as possible,” said officials. To achieve that goal, CMS plans to launch “in the very near future” a website dedicated to PDPM implementation and training, they revealed.
“Finally, we are working diligently as possible to develop and review revisions to the [RAI] Manual, data specifications, and other important aspects that vendors and other stakeholders will be looking for in order to develop products and training materials for PDPM implementation,” said officials. “We appreciate your patience as we complete this large body of work and will continue to endeavor to have all of these materials made available to the public as soon as possible.”
In the meantime, providers can still use the grouper tool and other PDPM tools (available here) that CMS developed in conjunction with the FY 2019 SNF PPS proposed rule as a reference to get a basic idea of how things will shake out under PDPM, said officials.
For example, the HIPPS codes in the updated grouper “should still remain a reflection of what they are in the current grouper” even though “the grouper itself is going to be slightly different,” said officials. The grouper logic will be changed to make it “more up to date with what the MDS [will] look like as of Oct. 1 of next year,” they explained.
SNF QRP Oct. 1 transition and dashes
Providers that don’t meet the 80 percent data completion threshold for the Skilled Nursing Facility Quality Reporting Program (SNF QRP) will have a 2 percent reduction in their market basket update in the applicable fiscal year, which is known as the SNF QRP annual payment update (APU). So it’s a big deal that CMS finally addressed how it would handle dashes for Medicare Part A residents who have a 5-day MDS with an assessment reference date (ARD) of 10-1-2018 forward but who started Medicare prior to 10-1 because some new MDS items, such as N2001 (drug regimen review), fell outside the assessment window and needed to be dashed.
“We do expect to receive dashes [for new MDS items that implemented on Oct. 1, 2018] for patients that were admitted into facilities prior to 10-1, and that will not be held against or count negatively toward the APU compliance,” explained officials.
SNF QRP warning messages on final validation reports
In conjunction with the Oct. 1 implementation of the revised MDS item sets, CMS now has three SNF QRP warning messages that could appear on final validation reports:
· 3897, Payment Reduction Warning: A dash (-) submitted in this quality measure item may result in a payment reduction for your facility of two percentage points for the affected payment determination.
· 3907, Payment Reduction Warning: A dash (-) submitted in all of the Self-Care and Mobility Discharge Goals quality measure items may result in a payment reduction for your facility of two percentage points for the affected payment determination.
· 3908, Payment Reduction Warning: If A0310H equals 1, a dash (-) submitted in this quality measure item may result in a payment reduction for your facility of two percentage points for the affected payment determination
When asked by a caller why uncoded discharge goals were receiving the 3907 warning message when the facility had coded one goal as required under the SNF QRP, officials pointed out that the warning edits “are linked to every GG goal that would satisfy the GG goal requirement for the process measure.”
So the warnings aren’t a definitive statement of noncompliance. “Those warning edits really serve to be a safety net and to be a double-check,” they stressed.
Note: For additional information on these warning errors and potential actions that SNFs may need to consider, see Section 5, “Error Messages,” of the MDS 3.0 Provider User’s Guide.
SNF QRP quarterly outreach
Under SNF QRP, providers have quarterly data reporting deadlines for meeting the 80 percent APU threshold requirement. For example, the reporting deadline for MDS data from April 1 – June 30, 2018, is Nov. 15, 2018. Note: See all calendar 2018 data collection requirements and related reporting deadlines for the FY2020 APU threshold requirement here.
Prior to each quarterly data submission deadline, CMS contractor CORMAC provides quarterly outreach informational e-mails to any SNFs that are in danger of failing to meet the 80 percent threshold for that quarter. This outreach requires that providers be signed up with a current e-mail address, pointed out officials.
Facilities that need to add or change the e-mail address that CORMAC uses to do quarterly outreach should e-mail QRPHelp@cormac-corp.com. “Please just request to receive this outreach, [and include] your facility name and CMS certification number (CCN),” said officials.
In other SNF QRP news, CMS doesn’t yet have a firm release date for an updated SNF QRP Measure Calculations and Reporting User’s Manual, said officials.
More Section GG webinars to come
CMS has received a significant number of questions regarding the Oct. 1 changes to Section GG (Functional Abilities and Goals). For example, several ODF callers questioned how to assess GG0170O (12 steps) if the therapy department only has a set of portable stairs with three steps. Officials declined to answer that specific question, but did note that, “in an effort to shore up and standardize all definitions, we are going to be creating some updated webinars, and we will deliver that information via our [SNF QRP] listserv.”
Note: Providers can submit questions related to the following SNF QRP issues to SNFQualityQuestions@cms.hhs.gov:
· MDS 3.0 coding instructions for Part A PPS Discharge assessment and Section GG;
· SNF QRP requirements;
· General quality reporting requirements and reporting deadlines;
· SNF QRP quality measures;
· Data reported in the SNF QRP CASPER Review and Correct reports; and
· Data reported in the SNF QRP CASPER Quality Measure reports.
Note: For more information about the regulatory requirements, see F-tag 943 (abuse, neglect, and exploitation training) in Appendix PP of the State Operations Manual. For registration or other technical questions about Hand in Hand, contact firstname.lastname@example.org. For nontechnical questions about Hand in Hand, contact email@example.com.
Several ODF callers expressed concern about the requirement for training volunteers, questioning whether one-time volunteers (e.g., entertainers) or volunteers who don’t interact with patients (e.g., lawn care volunteers) need training on dementia management and resident abuse prevention. CMS officials declined to answer, but it’s worth noting that F940 (training requirements—general), which implements on Nov. 28, 2019, specifies that training for volunteers, as well as staff and contractors, should be “consistent with their expected roles.”
Next PBJ deadline is Nov. 14
Staffing data for July 1 – Sept. 30, 2018, must be submitted by Nov. 14, 2018 (i.e., no later than 45 days from the end of the quarter), said officials. “We strongly encourage providers to submit data throughout the quarter and not wait until the last week before the deadline. Only data successfully submitted by the deadline is considered timely and used in the nursing home Five Star rating calculation. Once a facility uploads a data file, they need to check their final validation report … to verify that the data was successfully submitted. It may take up to 24 hours to receive the validation report, so providers must allow for time to correct any errors and resubmit if necessary.” Note: For information on how to access and read the PBJ final validation report, see the PBJ User Manual.
“Please note that the final validation report only confirms the data was submitted successfully. It does not confirm that the data submitted is accurate or complete,” stressed officials. “Facilities should review their monthly data preview in their CASPER folder for feedback on the most recent submission. We also encourage nursing homes to run CASPER reports 1700D (employee report), 1702D (individual daily staffing report), and/or 1702S (staffing summary report) prior to their submission before the quarterly deadline to review their data and ensure accuracy and completeness.”
Note: For information on how to access and interpret these reports, see Section 12, “PBJ Reports,” of the CASPER Reporting User’s Guide for PBJ Providers. For PBJ policy questions, contact firstname.lastname@example.org, and for PBJ technical questions, contact NursingHomePBJTechIssues@cms.hhs.gov.
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