• CMS QSO Memo: Enhanced Enforcement Actions Based on Nursing Home COVID-19 Data and Inspection Results (6/20)

    By CMS - June 02, 2020

    The Centers for Medicare & Medicaid Services (CMS) unveiled enhanced enforcement for nursing homes with violations of longstanding infection control practices. The enhanced and targeted accountability measures are based on early trends in the most recent data regarding incidence of COVID-19 in nursing homes, as well as data regarding the results of the agency’s targeted infection control inspections. CMS is increasing enforcement (e.g., civil money penalties (CMPs)) for facilities with persistent infection control violations, and imposing enforcement actions on lower level infection control deficiencies to ensure they are addressed with increased gravity.

    The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) provided additional funding to CMS for necessary survey and certification work related to COVID-19, of which $80 million in new resources will be available for states to increase surveys. To ensure effective oversight is achieved, CMS will allocate the CARES Act funding based on performance-based metrics. States that have not completed 100 percent of focused infection control surveys of their nursing home by July 31, 2020 will be required to submit a corrective action plan to their CMS location outlining the strategy for completion of these surveys within 30 days.  If, after the 30-day period, states have still not performed surveys in 100 percent of nursing homes, their CARES Act fiscal year 2021 allocation may be reduced by 10 percent.  Subsequent 30-day extensions could result in an additional 5 percent reduction. These funds would then be redistributed to those states that completed 100 percent of their focused infection control surveys by July 31.

    Utilizing the CARES Act funding, states will be required to perform on-site surveys of nursing homes with previous COVID-19 outbreaks and will be required to perform on-site surveys (within three to five days of identification) of any nursing home with new COVID-19 suspected and confirmed cases.

    To help nursing homes implement infection control best practices, CMS will provide technical assistance through Quality Improvement Organizations (QIOs). CMS and the Centers for Disease Control and Prevention (CDC) will continue to monitor the data it receives through the new nursing home COVID-19 surveillance system to identify nursing homes with outbreaks and work with Governor’s offices and states to keep nursing home residents safe.

    Since April 19, 2020, CMS has required nursing homes to inform, residents, their families, and representatives of COVID-19 cases in their facilities. For the first time, nursing homes are required to report COVID-19 cases and deaths directly to the CDC on an ongoing basis as the result of an unprecedented CMS regulatory requirement issued on May 1, 2020. The Trump Administration implemented the new reporting requirement to develop a robust federal disease surveillance system to quickly identify problem areas and inform future infection control actions. The reporting requirement applies to long-term care facilities only (also known as skilled nursing facilities and nursing facilities, and generally as nursing homes). By law, CMS regulates and oversees nursing homes, which are certified to provide Medicare and/or Medicaid skilled nursing facility services. Therefore, the data does not include COVID-19 data from assisted living facilities, which are not regulated at the federal level.

    As of May 24, 2020, about 12,500 nursing homes – approximately 80 percent of the 15,400 Medicare and Medicaid nursing homes – had reported the required data to the CDC. These facilities reported over 60,000 confirmed COVID-19 cases and almost 26,000 deaths. Of the nursing homes that reported data, approximately one in four facilities had at least one COVID-19 case, and approximately one in five facilities had at least one COVID-19 related death.  Early analysis shows that facilities with a one-star quality rating were more likely to have large numbers of COVID-19 cases than facilities with a five-star quality rating. CMS will take enforcement action against the nursing homes that have not reported data into the CDC as required under CMS participation requirements.

    CMS will post the underlying CDC-collected data on a link on Nursing Home Compare later this week, so the public can view general information of how COVID-19 has impacted nursing homes in a user-friendly format. The data will be broken down by state, number of residents and number of staff.  The data will be searchable by facility name and will be downloadable so researchers and other stakeholders can perform their own in-depth analysis.  CMS will update the data weekly. CMS will also post a link to the data on the home page of the Nursing Home Compare website so patients, residents, and families can easily find it. Nursing Home Compare is a valuable tool for patients, residents, and families to understand the quality of nursing homes and to support their healthcare decisions. Adding this information only increases its value and reinforces CMS’s commitment to transparency.

    CMS is ratcheting up penalties for noncompliance with infection control to help prevent backsliding, improve accountability, and ensure prompt compliance. Since February 2020 CMS has provided over 13 guidance documents and facts sheets pertaining to infection control and conducted weekly calls with nursing homes to share best practices from the field. The enhanced enforcement actions will increase penalties for nursing homes have had past infection control deficiencies.

    As part of CMS’s response to the COVID-19 pandemic, the agency prioritized the types of nursing home inspections that take place. On March 4, 2020 CMS prioritized inspections to allow inspectors to focus on the most serious health and safety threats like infectious diseases and abuse. On March 23, CMS suspended certain inspections to increase our focus on preventing the spread of COVID-19. Since March 4, CMS and its network of state-based inspectors have conducted over 8,300 surveys with the results of a total of 5,700 available today. There is currently wide variation in the number of focused infection control surveys of nursing homes performed by states, between 11.4 percent and 100 percent, with a national average of approximately 54.1 percent. CMS plans to post the results of the inspections later this week, on a monthly basis as they are completed.

    All of this information are being used to strengthen CMS enforcement action going forward, such that nursing homes are held accountable for resident care. Older Americans are particularly vulnerable to complications arising from the virus and nursing home residents have been uniquely affected. The Trump Administration is intensely focused on protecting this population, but it ultimately falls to the nursing homes themselves to ensure they provide care compliant with essential health and safety requirements.

    CMS is also providing additional support and technical assistance to low performing nursing homes through its QIOs. QIOs are organizations composed of health quality experts and clinicians that have experience in helping healthcare provider to improve the quality of care delivered to people with Medicare. CMS has now charged the QIOs to focus their efforts on providing education and training to all nursing homes in the country.  This will include weekly National Infection Control Training, which focuses on all aspects of infection control, prevention and management to help nursing homes prevent the transmission of COVID-19. 

    QIOs are also providing direct assistance to small and rural nursing homes and those serving vulnerable populations in areas where access to care is limited. The QIOs will help them understand and comply with CMS and CDC reporting requirements and, in some cases, they will provide on-site support to help nursing homes that have been identified as having the greatest needs in infection control. CMS will be working with Governors’ offices to direct QIOs to those nursing homes that have significant needs and have had outbreaks. QIOs will help these facilities create an action plan and implement specific steps to establish a strong infection control and surveillance program.

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  • What the MDS Changes to Pressure Ulcers Means for Care Processes

    By Emily Royalty-Bachelor, Staff Writer - May 21, 2020

    The way the nurse assessment coordinator (NAC) is tracking pressure ulcers may have changed, but that doesn’t mean the nursing team’s care process should.

    As part of its annual October updates to the RAI User’s Manual, the Centers for Medicare & Medicaid Services (CMS) made some changes to how pressure ulcers are referred to and how they are coded.

    First and foremost, the RAI manual has broadened the scope of its terminology, to include pressure injuries rather than just pressure ulcers.

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  • What Is That Annoying Noise?

    By Jane Belt, RN, MS, RAC-MT, QCP - May 21, 2020

    Visitors to nursing facilities often say, “What is that noise I keep hearing? It is so loud!” For those of us who work in the facilities, we get so that we hardly notice it. You know, of course, that “that noise” is the nerve-rattling sound of personal alarms.

     

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  • Three Ways to Guard Against a COVID-19 Surge in Your Building

    By Caralyn Davis, Staff Writer - May 20, 2020

    COVID-19 can spread like wildfire. In some facilities, the number of suspected or confirmed cases has surged from zero to fifty or more seemingly overnight. Here are three steps that nurse assessment coordinators (NACs) can take to mitigate the risk of severe COVID-19 spread among residents:

     

    Do COVID-19 surveillance on an independent track

    The Centers for Disease Control and Prevention (CDC) recommends that nursing homes that have no suspected COVID-19 residents actively screen all residents upon admission and at least daily for fever and symptoms of COVID-19 in order to immediately isolate symptomatic residents and implement transmission-based precautions. Note: This is consistent with April 2 and March 13 guidance from the Centers for Medicare & Medicaid Services (CMS) and should be done in conjunction with similar recommendations for screening staff, as well as all visitors to the facility, to ensure comprehensive surveillance.

     

    If presumptive or confirmed COVID-19 residents are identified in the facility, the CDC recommends that providers monitor symptomatic residents “(including documentation of temperature and oxygen saturation) at least 3 times daily to … identify and quickly manage serious infection” and also to “consider increasing monitoring of asymptomatic residents from daily to every shift to more rapidly detect any with new symptoms.” Note: This guidance is partially in Key Strategies to Prepare for COVID-19 in Long-term Care Facilities and partially in the Interim Additional Guidance.

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  • COVID-19 Infection Prevention and Wandering: Can the Two Co-Exist?

    By Caralyn Davis, Staff Writer - May 20, 2020

    In the March 13 revised Quality, Safety, and Oversight (QSO) memo QSO-20-14-NH, the Centers for Medicare & Medicaid Services (CMS) advised nursing homes to restrict all visitors except for compassionate-care situations and to “cancel communal dining and all group activities, such as internal and external group activities.” Adjusting to these changes has been difficult for every nursing home resident, but social distancing is especially hard for residents with dementia who wander and are eased by group activities.

     

    “That’s not who these people are,” acknowledges Teepa Snow, MS, OTR/L, FAOTA, founder and CEO of Positive Approach to Care, a global dementia care services and products company based in Efland, NC. “Nurses are being asked to do the impossible with the inadequate.”

     

    While physicians and physician extenders may be willing to prescribe an antipsychotic medication as an emergency measure in an acute or emergency situation as allowed under F758 (Free From Unnecessary Psychotropic Meds/PRN Use) in Appendix PP of the State Operations Manual, giving residents with dementia antipsychotics to make them immobile not only increases their risk of adverse events, such as cerebrovascular accidents (CVA) and even death, it also increases their risk of respiratory symptoms, including shortness of breath—one of the primary symptoms of COVID-19, points out Snow. “Providers may also consider taking away wheelchairs and other mobility aids. However, doing that puts residents with dementia at greater risk for falls and fall-related injuries, potentially resulting in a trip to the emergency department where they may be exposed to SARS-CoV-2, the virus that causes COVID-19.”

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  • COVID-19: CMS QSO Memo Details Nursing Home Reopening Recommendations for State and Local Officials (5/20)

    By CMS - May 19, 2020

    • Recommendations for State and Local Officials: CMS is providing recommendations to help determine the level of mitigation needed to prevent the transmission of COVID19 in nursing homes. The recommendations cover the following items:

    o Criteria for relaxing certain restrictions and mitigating the risk of resurgence: Factors to inform decisions for relaxing nursing home restrictions through a phased approach.

    o Visitation and Service Considerations: Considerations allowing visitation and services in each phase.

    o Restoration of Survey Activities: Recommendations for restarting certain surveys in each phase.

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  • Final MDS 3.0 Item Sets and Data Specifications for This October 1 Released (5/20)

    By CMS - May 18, 2020

    In response to State Medicaid Agency and stakeholder requests, CMS has updated the MDS 3.0 item sets (version 1.17.2) and related technical data specifications.  These changes will support the calculation of PDPM payment codes on OBRA assessments when not combined with the 5-day SNF PPS assessment, specifically the OBRA comprehensive (NC) and OBRA quarterly (NQ) assessment item sets, which was not possible with item set version 1.17.1.  This will allow State Medicaid Agencies to collect and compare RUG-III/IV payment codes to PDPM ones and thereby inform their future payment models.

    The changes to the technical data specifications that support these modifications are contained in the Errata v3.00.4 which can be accessed in the file: MDS 3.0 data specs errata (v3.00.4) Final 04-30-2020 in the Downloads section below. Supporting materials including the 1.17.2 Item Change History report and the revised 1.17.2 Item Sets can be accessed in the file:  MDS 3.0 Final Item Sets v1.17.2 for October 1 2020 zip also posted in the Downloads section below.

    Please confirm with your State Medicaid Agency if your State will be requiring the calculation of the PDPM payment codes on the OBRA assessments when not combined with a 5-day SNF PPS assessment.

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  • CMS COVID-19 Stakeholder Engagement Calls – Week of 5/18/20

    By CMS - May 18, 2020

    CMS hosts varied recurring stakeholder engagement sessions to share information related to the agency’s response to COVID-19. These sessions are open to members of the healthcare community and are intended to provide updates, share best practices among peers, and offer attendees an opportunity to ask questions of CMS and other subject matter experts.

    Call details are below. Conference lines are limited so we highly encourage you to join via audio webcast, either on your computer or smartphone web browser. You are welcome to share this invitation with your colleagues and professional networks. 

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  • LTCSP Survey Resources: Surveyor Tools Updated to Include COVID-19 (5/20)

    By CMS - May 18, 2020

    This ZIP file contains resources for surveyors conducting initial surveys under the Long-term Care Survey Process (LTCSP).

     

     05/14/2020 COVID-19 Focused Survey folder Updated the following:

    • F-Tag Job Aid- changed font color of F761 to black. Removed asterisks from F885.

    • Added updated F-Tag job aide to survey resources zip file.

     

    05/08/2020 COVID-19 Focused Survey folder Updated the following:

    • Summary of the COVID-19 Focused Survey for Nursing Homes Added to offsite survey activities-telephonic interviews of residents, representatives and families. Added review communication with residents, representatives and families. In the onsite survey activity section added in the interview section-information provided to residents concerning COVID-19. In the Facility Self-Assessment added Reporting to residents, families and representatives to priority areas. Added Reporting to CDC to priority areas.

    • COVID-19 Focused Survey Protocol Added information about the review of F884 by CMS Federal Surveyors. Added ACO coding information to off-site prep. Expanded information under offsite and onsite activities.

    • Entrance Conference Worksheet Clarified language under #9. Added #13 requesting information on facility’s mechanism for reporting COVID-19 to residents, representatives, and families.

    • COVID-19 Focused Survey for Nursing Homes Added two critical elements (CE) and adjusted the CE order. #7 CE Reporting to Residents, Representatives & Families, #8 Reporting to CDC, and #9 Emergency Preparedness.

    • F-Tag Job Aid- Added tags F884 and F885

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  • LTCSP Survey F-Tag List by Regulatory Grouping UPDATED and Additional Resources (5/20)

    By CMS - May 17, 2020
    These resources from CMS include a list of F-tags by regulatory grouping used in the Long-term Care Survey Process (LTCSP) effective Nov. 28, 2017, and a crosswalk between old and new F-tags. CMS updated the tag list in May 2020.
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  • CMS COVID-19 Emergency Declarations and Specific SNF/NF Flexibilities UPDATED (5/20)

    By CMS - May 15, 2020

    The blanket waivers were updated on May 15, 2020.

    Also Long Term Care Facilities (Skilled Nursing Facilities and/or Nursing Facilities): CMS Flexibilities to Fight COVID-19  was updated on May 15.  

    The update here is:

    **Paid Feeding Assistants: CMS is modifying the requirements at 42 CFR §§ 483.60(h)(1)(i) and 483.160(a) regarding required training of paid feeding assistants. Specifically, CMS is modifying the minimum timeframe requirements in these sections, which require this training to be a minimum of 8 hours. CMS is modifying to allow that the training can be a minimum of 1 hour in length. CMS is not waiving any other requirements under 42 CFR §483.60(h) related to paid feeding assistants or the required training content at 42 CFR §483.160(a)(1)-(8), which contains infection control training and other elements. Additionally, CMS is also not waiving or modifying the requirements at 42 CFR §483.60(h)(2)(i), which requires that a feeding assistant must work under the supervision of a registered nurse (RN) or licensed practical nurse (LPN).


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  • CDC Long-term Care COVID-19 Resources Updated (5/20)

    By CDC - May 14, 2020

    Interim Additional Guidance for Infection Prevention and Control for Patients with Suspected or Confirmed COVID-19 in Nursing Homes

     

    Summary of Changes to the Guidance:

    Updated guidance to recommend that nursing homes:

    • Act now to implement ALL COVID-19 preparedness recommendations, even before cases are identified in their community
    • Address asymptomatic and pre-symptomatic transmission, implement source control for everyone entering a healthcare facility (e.g., healthcare personnel, patients, visitors), regardless of symptoms.
    • Dedicate an area of the facility to care for residents with suspected or confirmed COVID-19; consider creating a staffing plan for that specific location


    COVID-19 Preparedness Checklist for Nursing Homes and other Long-Term Care Settings

    Nursing homes and other long-term care facilities can take steps to assess and improve their preparedness for responding to coronavirus disease 2019 (COVID-19). This checklist should be used as one tool to develop a comprehensive COVID-19 response plan, including plans for:

    • Rapid identification and management of ill residents
    • Considerations for visitors
    • Supplies and resources
    • Sick leave policies and other occupational health considerations
    • Education and training
    • Surge capacity for staffing, equipment and supplies, and postmortem care

    The checklist identifies key areas that long-term care facilities should consider in their COVID-19 planning. Long-term care facilities can use this tool to self-assess the strengths and weaknesses of current preparedness efforts. This checklist does not describe mandatory requirements or standards; rather, it highlights important areas to review to prepare for the possibility of residents with COVID-19.

     

    Additional pages: 


     


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  • Release of Updated MDS With New Standardized SPADEs (and Supporting Training) Delayed Due to COVID-19 Public Health Emergency (5/20)

    By CMS - May 13, 2020

    CMS is delaying the release of the updated versions of the Minimum Data Set (MDS) needed to support the Transfer of Health (TOH) Information Quality Measures and new or revised Standardized Patient Assessment Data Elements (SPADEs) in order to provide maximum flexibilities for providers of Skilled Nursing Facilities (SNFs) to respond to the COVID-19 Pubic Health Emergency (PHE).

    The release of updated versions of the MDS will be delayed until October 1st of the year that is at least 2 full fiscal years after the end of the COVID-19 PHE. For example, if the COVID-19 PHE ends on September, 20, 2020, SNFs will be required to begin collecting data using the updated versions of the item sets beginning with patients discharged on October 1, 2022.

    Following the PHE, CMS will announce training opportunities for providers via this webpage and announcements sent out via email distribution lists and posted on the Medicare Learning Network.

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  • CMS QSO Memo updates F-tags and COVID-19 Focused Survey Tools to Include Reporting Requirements (5/20)

    By CMS - May 07, 2020
    Interim Final Rule Updating Requirements for Notification of Confirmed and Suspected COVID-19 Cases Among Residents and Staff in Nursing Homes

    Memo # QSO-20-29-NH

    Posting Date 2020-05-06

    Fiscal Year 2020

     

    Summary

    • CMS is committed to taking critical steps to ensure America’s healthcare facilities are prepared to respond to the Coronavirus Disease 2019 (COVID-19) Public Health Emergency (PHE).

    • On May 8, 2020, CMS will publish an interim final rule with comment period. • COVID-19 Reporting Requirements: CMS is requiring nursing homes to report COVID-19 facility data to the Centers for Disease Control and Prevention (CDC) and to residents, their representatives, and families of residents in facilities.

    • Enforcement: Failure to report in accordance with 42 CFR §483.80(g) can result in an enforcement action.

    • Updated Survey Tools: CMS has updated the COVID-19 Focused Survey for Nursing Homes, Entrance Conference Worksheet, COVID-19 Focused Survey Protocol, and Summary of the COVID-19 Focused Survey for Nursing Homes to reflect COVID-19 reporting requirements.

    • COVID-19 Tags: F884 and F885.

    • Transparency: CMS will begin posting data from the CDC National Healthcare Safety Network (NHSN) for viewing by facilities, stakeholders, or the general public. The COVID-19 public use file will be available on https://data.cms.gov/.

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  • To IPA or NOT To IPA: That Is an Important Question

    By Carol Maher, RN-BC, RAC-MTA, RAC-MT, RAC-CTA, RAC-CT, CPC - May 05, 2020

    Healthcare professionals were relieved when CMS agreed to make the Interim Payment Assessment (IPA) optional instead of a requirement. This meant that skilled nursing facilities (SNFs) could decide when or if they would complete these payment assessments. CMS anticipated that SNFs would perform IPAs during each Medicare Part A stay both to improve Medicare payment during the stays and to monitor patients’ clinical status. However, data shows that few IPAs are being completed.

     

    One likely reason why: the complexity of the new Patient-Driven Payment Model (PDPM) makes it difficult to know when an MDS would improve the final payment. John Kane, CMS’s SNF Payment Team Lead, stated during one of CMS’s train-the-trainer sessions that there could be as many as 1,900 possible payment combinations per PPS MDS.

     

    So how can you know whether an IPA would improve the Medicare payment? First, let’s consider the impact of CMS’s original plan to require the IPAs. CMS proposed that IPAs would be completed when there was a change in one of the first-tier classification criteria in any of the proposed payment components. For example, if the resident had been classified into the Major Joint Replacement category for the PT/OT component and their primary diagnosis changed to Medical Management, the IPA would have been required. Likewise, when a resident’s Nursing component category changed from Extensive Services to Special Care Low, an IPA would have been required. We are grateful that assessments are not mandatory in these circumstances, but they provide a useful starting point for understanding when an IPA could be financially beneficial.

     

    In the SNF PPS Final Rule for FY 2020, CMS included the following table showing the FY 2020 federal unadjusted urban base rates for each of the six PDPM payment components:

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