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Under the Patient-Driven Payment Model (PDPM) in the Skilled Nursing Facility Prospective Payment System (SNF PPS), the Interim Payment Assessment (IPA, A0310B = 08) will be the only tool providers have to increase the per-diem rate once it’s set by the 5-day PPS MDS, says Scott Heichel, RN, RAC-MT, DNS-CT, QCP, CIC, director of clinical reimbursement for LeaderStat in Powell, Ohio.
“The optional IPA can be used any time in between the 5-day PPS assessment and the Part A PPS Discharge assessment to capture payment increases when the characteristics of the resident change to a level that it actually affects the PDPM calculation in one or more of the five case-mix-adjusted payment categories: physical therapy (PT), occupational therapy (OT), speech-language pathology (SLP), nursing, or nontherapy ancillaries (NTA),” explains Heichel.
To prepare to make optimal use of the IPA, nurse assessment coordinators (NACs) should consider taking the following steps:
While no new items in section K of the MDS are expected this October, the Patient-Driven Payment Model (PDPM) is a game changer and some of the existing section K items are going to get a lot more attention. While swallowing and nutritional status have always been important for care areas and care planning, starting October 1, section K steps into the reimbursement spotlight for the speech-language pathology (SLP) component of PDPM. Not to mention, other key MDS items, like parenteral/IV feedings, tube feeding, and intake by artificial route, which currently impact reimbursement, will have even more pull under PDPM.
SNF users were notified by CMS on Monday, March 11, that the Review and Correct report in the ‘SNF Quality Reporting Program ‘ category in the CASPER Reporting application would be unavailable while enhancements were being applied to the report. This report is now available and contains the following enhancements:
• The addition of two new measures starting April 1, 2019:
-Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury
-Drug Regimen Review Conducted with Follow-up for Identified Issues – PAC SNF QRP
• The removal of one measure starting with Q4 2018 results:
-Percent of Residents or Patients with Pressure Ulcers That are New or Worsened (Short Stay) (NQF#0678)
• The addition of Resident-Level data will now display with the Facility-Level data results.
-A .csv file output will be available for the Patient-Level data
• The Resident-Level and Facility-Level data will have new filter/sorting functionality within the CASPER Report Submit screen to customize the reporting results.
CR 11152 effectuates changes to the SNF Prospective Payment System (PPS) that are required for the PDPM. These changes were finalized in the FY 2019 SNF PPS Final Rule (83 FR 39162). SNFs billing on Type of Bill (TOB) 21X and hospital swing bed providers billing on TOB 18X, (subject to SNF PPS) will be subject to these requirements. Make sure your billing staff is aware of these changes.
Nurse assessment coordinators (NACs) should prepare their administrative team for some upheaval in their star ratings effective April 24, 2019. The Centers for Medicare & Medicaid Services (CMS) is making changes to the Five-Star Quality Rating System that will impact all three Five-Star domains: the Health Inspection domain, the Staffing domain, and the Quality Measures (QM) domain.
Specialized Infection Prevention and Control Training for Nursing Home Staff in the Long-Term Care Setting is Now Available
The Centers for Medicare & Medicaid Services (CMS) and the Centers for Disease Control and Prevention (CDC) collaborated on the development of a free on-line training course in infection prevention and control for nursing home staff in the long-term care setting.
The training provides approximately 19 hours of continuing education credits as well as a certificate of completion (i.e., free CME, CNE or CEUs).
The course introduces and describes how to use IPC program implementation resources including policy and procedure templates, audit tools, and outbreak investigation tools.
The course is made up of 23 modules and sub-modules that can be completed in any order and over multiple sessions.
The course covers:
The Immediate Jeopardy Update Training introduces surveyors and non-surveyors to the revised Appendix Q–Core Guidelines to Determining Immediate Jeopardy. The Core Appendix Q focuses on the key components necessary to establish immediate jeopardy (IJ) under the regulations.
These key components are:
The Core Appendix Q also contains information about how surveyors should determine whether IJ exists, and it includes a template that surveyors must use to ensure that sufficient evidence exists for each key component of IJ.
The SNF consolidated billing file reflects new codes that have been developed for 2019. In addition, the file reflects additions to categories of services excluded from consolidated billing.
The annual update file below contains the complete list of HCPCS codes that are excluded from SNF CB for claims submitted to Part A MACs for payment. Minor Surgery and Part B therapy inclusions are also included with this file. This file is effective for claims with dates of service on or after 1/1/2019 unless otherwise noted .
Core Appendix Q and Subparts - Appendix Q to the State Operations Manual (SOM), which provides guidance for identifying immediate jeopardy, has been revised. The revision creates a Core Appendix Q that will be used by surveyors of all provider and supplier types in determining when to cite immediate jeopardy. CMS has drafted subparts to Appendix Q that focus on immediate jeopardy concerns occurring in nursing homes and clinical laboratories since those provider types have specific policies related to immediate jeopardy.
Key Components of Immediate Jeopardy – To cite immediate jeopardy, surveyors determine that (1) noncompliance (2) caused or created a likelihood that serious injury, harm, impairment or death to one or more recipients would occur or recur; and (3) immediate action is necessary to prevent the occurrence or recurrence of serious injury, harm, impairment or death to one or more recipients.
Immediate Jeopardy Template – A template has been developed to assist surveyors in documenting the information necessary to establish each of the key components of immediate jeopardy. Survey teams must use the immediate jeopardy template attached to Appendix Q to document evidence of each component of immediate jeopardy and use the template to convey information to the surveyed entity.
With the next version of the RAI User’s Manual not slated to be released until late spring, there are still some unknowns about the new Interim Payment assessment (IPA), but the Centers for Medicare & Medicaid Services (CMS) has established the basic rules of the road. Here’s a handy summary of the information CMS has provided thus far.
Creating successful partnerships with Medicare accountable care organizations (ACOs) can seem like a daunting task for many skilled nursing facilities (SNFs), but with the right tools and strategic approaches, these relationships can be the cornerstone to clinical, and operational, success. Below are a few tips to assist in ACO success.
The April 2019 changes include revisions to the inspection process, enhancement of new staffing information, and implementation of new quality measures.
This includes a lifting of the ‘freeze’ on the health inspection ratings instituted in February 2018. CMS ‘froze’ the health inspection star ratings category after implementing a new survey process for Long-Term Care facilities. Because facilities receive surveys at different times, some facilities would have been surveyed under the old process and others under the new process. Without placing a ‘freeze’ on health inspection star ratings, the facilities would have been scored using two different evaluation processes making the outcomes misaligned and the data inaccurate. CMS ‘froze’ the health inspection star rating score until all nursing homes were surveyed at least once under the new survey process for Long Term Care facilities. Ending the freeze is critical for consumers. In April, they will be able to see the most up to date status of a facility’s compliance, which is a very strong reflection of a facility’s ability to improve and protect each resident’s health and safety.
Additionally, CMS is setting higher thresholds and evidence-based standards for nursing homes’ staffing levels. Nurse staffing has the greatest impact on the quality of care nursing homes deliver, which is why CMS analyzed the relationship between staffing levels and outcomes. CMS found that as staffing levels increase, quality increases and is therefore assigning an automatic one-star rating when a Nursing Home facility reports “no registered nurse is onsite.” Currently, facilities that report seven or more days in a quarter with no registered nurse onsite are automatically assigned a one-star staffing rating. In April 2019, the threshold for the number of days without an RN onsite in a quarter that triggers an automatic downgrade to one-star will be reduced from seven days to four days. CMS is also making changes to the quality component on Nursing Home Compare that would improve identifying differences in quality among nursing homes, raise expectations for quality, and incentivize continuous quality improvement.
To provide further value and remain consistent with CMS’s Meaningful Measures initiative the April 2019 Nursing Home Compare Update includes adding measures of long-stay hospitalizations and emergency room transfers, and removing duplicative and less meaningful measures. CMS is also establishing separate quality ratings for short-stay and long-stay residents and revising the rating thresholds to better identify the differences in quality among nursing homes making it easier for consumers to find the right information needed to make decisions.
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