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Q&A: Our facility lost 2% of the Medicare annual payment update due to noncompliance with the SNF QRP. How can we determine what caused our low percentage?

By Carol Maher, RN-BC, CPC, RAC-MT - July 23, 2018

QuestionOur facility lost 2% of the Medicare annual payment update (APU) next year due to missing QPR data. Although we have read through all of the resources, we are still unclear on what is causing the non-compliance and so we are unsure how to resolve the issues for this year so that payment is not affected for 2020. We know that we cannot use dashes for MDS items used to calculate the SNF QRP measures.Is there a way to ascertain what may be contributing to the low percentage of compliance?

Answer: CMS now has the SNF QRP facility level and resident level reports on the CASPER site that allow you to drill down to which residents and/or stays contained the dashes.

One issue that could be contributing would be if HMO Medicare Advantage 5-day assessments had been transmitted. Often times these assessments contain dashes and NPEs are not done for HMO payers. The dashes on these submitted assessments would count against you. Also, because you submitted a 5-day, the program may consider the NPE as missing, which would also count against you.

Another issue might be the wheelchair items in section GG if any have been identified as non-compliant. Often dashes are found in those items and can be corrected through the modification process.

The number one thing that you can do now is to develop strong systems for assessing new Medicare admissions and assessing again at the end of the Medicare stay. Don’t expect your therapists to manage this process on their own. New admissions often discharge before therapy has started, which could result in dashes.  Also consider that not every resident requires therapy on admission or could be finished with therapy prior to the last three days of the Medicare stay.

Best practice would be to ensure collaboration between nursing and therapy. Nurses should complete a nursing assessment for all new admissions/readmissions. The section GG items can be included in that nursing assessment. If therapy evaluates the resident within the first three days, the therapists can also assess the resident’s performance for those GG items. In your daily PPS meeting, therapy and nursing can compare the results of those assessments so that a coding decision can be made within the first and last three days. The discharge goal can be set with input from the therapists when completing the 5-day PPS MDS.

In addition to the section GG items, also identify dashes used in the MDS items used to calculate the SNF QRP measures for falls with major injury and new or worsened pressures ulcers, which may have also impacted your compliance.

Want to read more FAQs? Visit the AANAConnect community , where 14,000+ of your peers and experts in long-term care are asking and answering tough questions just like this.

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