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Meeting and discussing with hundreds of nurse assessment coordinators (NACs) and fielding a wide array of questions about the Resident Assessment Instrument (RAI) process, the Minimum Data Set (MDS), Care Area Assessments (CAAs), and person-centered care plans over the years, it seemed a relatively easy assignment to discuss using deficiency data to provide useful information for the NAC. Survey data also abounds with the full text of statement of deficiencies posted monthly on the Centers for Medicare & Medicaid Services’ (CMS’s) Five-Star Quality Rating System website. With the help of a data analyst, we sifted through over 3,000 records. We looked at the numbers, determined the types of citations most often encountered by the NACs, and identified key issues and trends. To say the least, the data forced this writer to take a new approach and figure out a new angle to tackle the task, , as the cited deficiencies seemed to be much of the information that we have read before when looking at the most frequently cited F-tags. So what does the NAC need to consider in order to avoid the common pitfalls that we often see when the surveyors comb through the records?
Revisions in the April 11 update of Patient-Driven Payment Model: Frequently Asked Questions (FAQs) suggest that the Optional State Assessment (OSA) is no longer a temporary assessment, meaning that it may remain active—and its use may actually expand—in some states for longer than the one fiscal-year (FY) transition period originally set by the Centers for Medicare & Medicaid Services (CMS). Therefore, it’s more vital than ever for nurse assessment coordinators (NACs) in Medicaid case-mix states to understand the OSA and how the October 1 transition of the Medicare Part A Skilled Nursing Facility Prospective Payment System (SNF PPS) to the Patient-Driven Payment Model (PDPM) case-mix classification system from the RUG-IV system can impact their Medicaid nursing facility (NF) payments.
On April 19, the Centers for Medicare & Medicaid Services (CMS) publicly posted the fiscal year (FY) 2020 Skilled Nursing Facility Prospective Payment System (SNF PPS) Proposed Rule (CMS-1718-P). While the proposed rule updates the Medicare Part A federal per-diem payment rates, those changes are somewhat overshadowed by multiple proposed policy changes focusing on these key areas:
Specifications for the quality measures and standardized patient assessment data elements for the SNF QRP as proposed in the FY 2020 SNF PPS Proposed Rule are now posted.
In addition, the new and modified sections of the MDS, along with a change table, effective October 1, 2020 for the measures and standardized patient assessment data elements proposed for the SNF QRP in the FY 2020 SNF PPS Proposed Rule are available.
Proposed Fiscal Year 2020 Payment and Policy Changes for Medicare Skilled Nursing Facilities (CMS-1718-P)
On April 19, 2019, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule [CMS-1718-P] for Fiscal Year (FY) 2020 that updates the Medicare payment rates and the quality programs for skilled nursing facilities (SNFs). This proposed rule is part of our continuing efforts to strengthen the Medicare program by better aligning payment rates for these facilities with the costs of providing care and increasing transparency so that patients are able to make informed choices. Additionally, effective October 1, 2019, CMS will begin using a new case-mix model, the Patient Driven Payment Model (PDPM), which focuses on the patient’s condition and resulting care needs rather than on the amount of care provided in order to determine Medicare payment.
This fact sheet discusses three major provisions of the proposed rule: the proposed changes to SNF payment policy under the SNF Prospective Payment System (PPS), the SNF Value-Based Purchasing Program (VBP), and the SNF Quality Reporting Program (QRP). This proposed rule includes policies that would continue a commitment to shift Medicare payments from volume to value, with the continued implementation of the PDPM, SNF VBP, and SNF QRP to improve program interoperability, operational quality and safety.
CMS created the Five-Star (5-Star) Quality Rating System to help consumers, their families, and caregivers compare nursing homes more easily. The Five-Star Quality Rating System Technical Users' Guide provides in-depth descriptions of the ratings and the methods used to calculate them. Updated twice in April 2019.
The Five Star Preview Reports will be available on April 17, 2019. To access these reports, select the CASPER Reporting link located on the CMS QIES Systems for Providers page. Once in the CASPER Reporting system, select the 'Folders' button and access the Five Star Report in your 'st LTC facid' folder, where st is the 2-character postal code of the state in which your facility is located and facid is the state-assigned Facility ID of your facility.
Nursing Home Compare will update with April's Five Star data on April 24, 2019.
Important Note: The 5 Star Help line (800-839-9290) will be available April 22, through May 3, 2019. Please direct your inquiries to BetterCare@cms.hhs.gov if the Help Line is not available.
This section includes fact sheets on a variety of PDPM related topics.
PDPM Frequently Asked Questions
This section contains frequently asked questions (FAQs) related to PDPM policy and implementation. The PDPM FAQs were updated on 4-4 and then again on 4-11.
When the Patient-Driven Payment Model (PDPM) implements as the case-mix classification system for the skilled nursing facility prospective payment system (SNF PPS) on Oct. 1, 2019, SNFs will have to code a new set of health insurance prospective payment system (HIPPS) codes in MDS item Z0100A (Medicare Part A HIPPS code) and on the Part A claim to identify a SNF resident’s payment classification, pointed out officials with the Centers for Medicare & Medicaid Services (CMS) during the Dec. 11 SNF PPS: PDPM National Provider Call.
The Skilled Nursing Facility Quality Reporting Program (SNF QRP) is an annual program, meaning SNFs must continuously strive to avoid each fiscal year’s two percent SNF QRP data submission penalty for failing to meet the data submission threshold requirement, also known as the annual payment update (APU) requirement, as well as to ensure the accuracy of their SNF QRP quality measures (QMs) for public reporting.
The way that the SNF QRP is set up, SNFs often have to work on two program years simultaneously. This overlap happens because there is a lag of four and one-half months between the close of a reporting quarter and its data submission deadline. For example, providers currently are finalizing calendar fourth-quarter 2018 MDS data to meet the last reporting deadline, for the FY 2020 (Oct. 1, 2019 – Sept. 30, 2020) program year. Since Jan. 1, SNFs also have been submitting calendar 2019 MDS data in preparation for the upcoming reporting deadlines for the FY 2021 (Oct. 1, 2020 – Sept. 30, 2021) submission requirements.
Providers need to understand the timeline of what happens when so they can have systems in place to identify and address potential problems timely. Key points in the timeline are discussed below and pulled together into the chart, “Key Dates Impacting Each Fiscal Year’s APU Payment Determinations,” at the end of this article.
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