Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency
Last week, the Government announced and published the ideas and concepts for Skilled Nursing Payments for Medicare Part A Beneficiaries effective October 2017 (Fiscal Year 2018). CMS (Centers for Medicare & Medicaid Services) authored the documents and awaits feedback from the industry. Upon review of the responses, CMS will adjust and release a Final Rule within approximately 60 days (July 2017).
- The proposed rule for FY 2018 establishes a net market basket increase of 1.0%.
- Project payments to SNFs to increase in FY 2018 by $390 million.
- Revisions to the RoP (Requirements of Participation) that seem to be far-reaching and excessive for effective implementation.
- 2% Penalty for not meeting the reporting requirements of the SNF Quality Reporting Program (SNFQRP).
- Quality Reporting Program (QRP): Modifications to existing SNF QRP measures as well as adoption of additional measures.
- Acquired Immune Deficiency Syndrome (AIDS) increase of 128 percent since October 1, 2004 remains in effect for FY 2018.
- SNF Value-Based Purchasing (VBP) Program: Discussion on an equation to calculate the payment amount from the performance measure. In addition, how the Government will communicate said performance results (Report).
Remember: VBF is comprised of 3 components:
- Measurement (Hospital Readmissions)
- Report (referenced above)
- Reward (2%)
Other areas discussed in the Proposed Rule for SNF Value-Based Purchasing (VBP)
- Size of Incentive Pool: Total amount of funds available for incentive payments for qualifying facilities in a fiscal year would be 60 percent of the amounts withheld from SNFs’ Claims.
- Inclusion/Exclusion of Smaller SNFs: CMS is seeking feedback to ensure that SNFs that are meeting quality goals are not wrongfully penalized.
- Exchange Function to Determine Payment Adjustment: CMS proposes to use a logistic function for the FY 2019 SNF VBP Program and subsequent years.
- Public Reporting: CMS proposes to begin publishing SNF performance data on Nursing Home Compare no later than October 1, 2017, and indicates that it will only publish performance information for which SNFs have had the opportunity to review and submit corrections. In addition, CMS proposes to publish SNF ranking data on both the Nursing Home Compare and Quality Net websites after August 1, 2018, when performance scores and incentive payments will be made. CMS intends to publish the ranking for each program year once performance scores and incentive payments are available to SNFs.
- Measurement Change: From SNFRM Measure to SNFPPR Measure in the FY 2021 program year.
- Skilled Nursing Facility (SNF) Quality Reporting Program (QRP)
- Replace the current pressure ulcer measure Pressure Ulcers That Are New or Worsened (Short Stay) (NQF #0678) and to replace it with Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury.
- Adopt the following from IRF (Inpatient Rehabilitation Facilities) Functional Outcome Measures:
- Change in Self-Care Score (NQF #2633)
- Change in Mobility Score (NQF #2634)
- Discharge Self-Care Score (NQF #2635)
- Discharge Mobility Score (NQF #2636)
- Modify Two Current SNF QRP Measures:
- Potentially Preventable 30-Days Post-Discharge Readmission Measure for Skilled Nursing Facility: Increase the length of the measurement period from 1 year to 2 years of claims data to expand the number of SNFs that meet the minimum stays threshold for public reporting. Additional modification would update the public reporting dates for this measure from calendar year to fiscal year.
- Discharge to Community-PAC SNF QRP Measure: Exclude baseline nursing facility residents from the measure, as these residents did not live in the community prior to the SNF stay.
- Public Display of SNF QRP Measure Data in Calendar Year 2018 for the measures currently in use:
- Assessment-Based Measures:
- Long-Term Care Hospital (LTCH) Patients With an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631)
- Pressure Ulcers That Are New or Worsened (NQF #0678)
- One or More Falls with Major Injury (NQF# 0674)
- Claims-Based Measures:
- Medicare Spending Per Beneficiary
- Discharge to Community
- Potentially Preventable 30-Day Post-Discharge Readmission Measure
- Assessment-Based Measures:
- Survey Team: The Government is suggesting that complaint surveys subscribe to the requirement of 488.332, which states a registered nurse is not necessary to participate on the survey team.
I know this is a significant amount of information to assimilate into the working knowledge of your day to day operations. Awareness is the most important element today. Please note that there is also information on the proposed payment system. Harmony Healthcare International (HHI) will publish blogs on these components later this month.
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