Blog by:  Shelly Maffia, MSN, MBA, RN, LNHA, QCP, CHC, Director of Regulatory Services, Proactive Medical Review

On 08/17/2020 CMS announced that they are revising guidance on the expansion of survey activities to authorize onsite revisits and other surveys, and guidance was provided to State Survey Agencies (SA) on resolving previously “on hold” enforcement cases. A temporary expansion to the desk review policy was also announced.

Background & Recent Updates

On June 1, 2020 CMS issued survey reprioritization guidance to transition States to more routine oversight and survey activities once a State has entered Phase 3 of the Nursing Home Reopening Guidance. At that time, states were authorized to expand beyond conducting only IJ, Focused Infection Control, and Initial Certification survey, and were permitted to resume the following types of surveys, at the state’s discretion:

  • Complaint investigations that are triaged as Non-Immediate Jeopardy-High;
  • Revisit surveys of any facility with removed Immediate Jeopardy (but still out of compliance);
  • Special Focus Facility and Special Focus Facility Candidate recertification surveys; and
  • Nursing home and Intermediate Care Facility for Individuals with Intellectual Disabilities (ICF/IID) recertification surveys in facilities where it has been over 15 months since the last standard survey.

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About Proactive Medical Review
HTS partners with Proactive Medical Review, a third party company who specializes in ensuring compliance with regulatory standards and promoting measurable care excellence. The team includes SNF experienced nurse, MDS, Health Facility Administrator, therapist and reimbursement specialists with experience serving in multi-site contract therapy operations, as corporate directors of quality, clinical program specialists, and Compliance Officers. Proactive is uniquely positioned to assist in managing the many changes and challenges facing providers partnered with HTS. Learn more about our commitment to compliance here.

On July 24, 2020 CMS released a SNF QRP COVID-19 Tip Sheet. Here’s what you need to know:

  • Starting on July 1, 2020, SNFs are expected to resume timely quality data collection and submission of measure and patient assessment data for the MDS/RAI.
  • Specific quarters requiring reporting of data for the QRP program for CYs 2019 and 2020 are listed below:October 1, 2019–
    • December 31, 2019 (Q4 2019)
    • January 1, 2020–March 31, 2020 (Q1 2020)
    • April 1, 2020–June 30, 2020 (Q2 2020)
  • The MDS should be submitted for all new admission records and discharge records that occur on or after July 1, 2020.
  • Timely submission and acceptance requirements of MDS data to meet the 80-percent threshold are unchanged. SNFs are required to submit at least 80 percent of the necessary data to calculate the SNF QRP quality measures.
  • Before QM data is publicly reported on Nursing Home Compare, SNFs have the opportunity to review and correct and/or preview their data. A quarterly Provider Preview Report can be accessed via the Certification and Survey Provider Enhanced Reports (CASPER) application which is accessible from a SNF’s “Welcome to the CMS QIES Systems for Providers” page. Full instructions are available here.

 

Did You Know?

As part of the HTS Partner Plus Program you get access to multiple MDS specialists and nursing consultants to assure your coding is accurate which not only impacts PDPM reimbursement but also QRP? Contact HTS Director of Clinical Outcomes today for more details at sheena@htstherapy.com.

On July 31, 2020, the Centers for Medicare & Medicaid Services (CMS) issued a final rule that updates the Medicare payment rates and the quality programs for SNFs.

These updates include routine technical rate-setting updates to the SNF PPS payment rates, as well as finalizes adoption of the most recent OMB statistical area delineations and applies a 5 percent cap on wage index decreases from FY 2020 to FY 2021.

CMS is also finalizing changes to the ICD-10 code mappings that would be effective beginning in FY 2021, in response to stakeholder feedback. CMS projects aggregate payments to SNFs will increase by $750 million, or 2.2 percent, for FY 2021 compared to FY 2020.

Updated Base Rates for PDPM Components

For FY 2021, the unadjusted federal rate per diem for urban and rural will be as follows, prior to adjustment for case-mix.

TABLE 3: FY 2021 Unadjusted Federal Rate Per Diem – URBAN

Table 4: FY 2021 Unadjusted Federal Rate Per Diem – RURAL

Click here to view the SNF PPS Final Rule Fact Sheet.

Link to the Final Rule – http://www.federalregister.gov/inspection.aspx

Source: Centers for Medicare & Medicaid Services, www.cms.gov

CMS posted initial data analytics on COVID-19. Data was collected from nursing home reports to the CDC’s National Healthcare Safety Network. Data will be updated on a weekly basis moving forward.

COVID-19 Focused Survey Items for Nursing Homes to be Completed by July 31, 2020

Indiana COVID-19 Updates and Resources

Kentucky COVID-19 Updates and Resources

What can providers do?

For questions or additional information, contact your Regional Director or Cassie Murray.

Blog by Cassie Murray, OTR, MBA, QCP, Chief Operating & Clinical Officer

During the May 12th CMS Office Hours broadcast, CMS provided guidance for SNF therapists to include the time spent donning and doffing PPE in the MDS Section O minutes. Therapists should begin including this time in the total treatment time for each session. This topic is covered in the recorded podcast between time markers 3:02 and 3:54. The link below is to the recording and written transcript.

Tuesday, May 12, 2020, CMS Office Hours (ZIP)

For questions or additional information, contact your Regional Director or Cassie Murray.

Blog by:  Shelly Maffia, MSN, MBA, RN, LNHA, QCP, CHC, Director of Regulatory Services, Proactive Medical Review

As part of President Trump’s Guidelines for Opening Up America Again, the Centers for Medicare and Medicaid Services (CMS) announced new nursing home reopening recommendations for state and local officials. These recommendations detail criteria for relaxing certain restrictions and mitigating the risk of resurgence, visitation and service considerations, and restoration of survey activities.

The guidance encourages state leaders to collaborate with the state survey agency and state and local health departments to decide how these criteria or actions should be implemented in their state and provides examples of how a State may choose to implement the recommendations, which includes options of states to require that all facilities go through each phase at the same time, allowing facilities in a certain region within the state to enter each phase at the same time, or permitting individual facilities to move through each phase based on their status for meeting the criteria for each phase.

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About Proactive Medical Review
HTS partners with Proactive Medical Review, a third party company who specializes in ensuring compliance with regulatory standards and promoting measurable care excellence. The team includes SNF experienced nurse, MDS, Health Facility Administrator, therapist and reimbursement specialists with experience serving in multi-site contract therapy operations, as corporate directors of quality, clinical program specialists, and Compliance Officers. Proactive is uniquely positioned to assist in managing the many changes and challenges facing providers partnered with HTS. Learn more about our commitment to compliance here.

Update on CMS & MAC Claims Processing

Below is an update from AHCA on processing of Medicare claims under the Patient-Driven Payment Model. Please note particularly the part that suggests holding claims until Thursday, October 24.

On October 17th, CMS transmitted is quarterly update to all Medicare Administrative Contractors (MACs) as scheduled. CMS also indicated the MACs would need until October 24th to load, test, and launch the update.

Today, we have heard from several members about problems with claims submitted last Friday and yesterday. This likely is because the MACs require more time (e.g., until the targeted October 24th) to finish installation and testing.

Last evening, we informed CMS (both payment policy staff as well as MAC officers about the responses from MACs to-date (e.g., lower likely payments than billed). We will remain in contact with CMS in the coming days.

For now, we recommend holding submission of claims until October 24th – the date CMS indicated the MACs should be ready. On October 25th, COB, we will be in contact with membership about the result of claims submission. If problems persist, AHCA will escalate the issue quickly.

The final submission deadline for this quarter is November 14th, 2019. Only data successfully submitted by this time is used on the Nursing Home Compare website and in the five star rating calculations.

Tips:

  • Once information is uploaded, check your Final Validations Report which is accessed in the Certification and Survey Provider Enhanced Reporting (CASPER folder) to verify data was submitted successfully.
  • It may take up to 24 hours to receive the validation report.
  • QIES helpdesk is available for assistance help@qtso.com
  • Do not wait until just a few days before the deadline to submit PBJ data for the reasons above.

Click here to learn more.

CMS announced the MDS 3.0 RAI Manual v1.17.1 which will take effect on October 1, 2019 is now available. 
This version of the RAI manual provides clarification to existing coding and transmission policy.

Click here to download the manual.

Article by Cassie Murray, OTR, QCP, IASSC CYB, Chief Operating & Clinical Officer, Healthcare Therapy Services, Inc.

On Friday 4/19, CMS released the pre-publication of the FY 2020 Skilled Nursing Facility Prospective Payment System Proposed Rule. As expected, the Patient-Driven Payment Model is confirmed to go into effect October 1, 2019.
SNF Proposed Payment Updates for FY 2020:

  • Proposed SNF payment update is 2.5% (increase of $887 million from FY2019)
  • The proposed updated Base Rates for the PDPM Components (unadjusted federal per diem rates for urban and rural):

TABLE 3: FY 2020 Unadjusted Federal Rate Per Diem–URBAN

TABLE 4: FY 2020 Unadjusted Federal Rate Per Diem-RURAL

SNF Quality Reporting Program:

  • For FY 2022, CMS proposes the adoption of two process measures:
    • Transfer of Health Information to the Provider-Post-Acute Care.
    • Transfer of Health Information to the Patient-Post-Acute Care.
  • CMS proposes to update specifications for Discharge to the Community SNF QRP Measure to exclude baseline nursing facility residents from the measure.
  • CMS proposes to collect standardized patient assessment data using MDS for all patients regardless of payer source.

PDPM Changes:

  • CMS proposes to change the SNF group therapy definition to match the IRF group therapy definition. This would allow for qualified therapists or assistants to treat two to six patients in a group performing the same or similar activities.
  • CMS proposes that non-substantive updates to ICD-10 codes used in PDPM be made through the PDPM website. Substantive changes would continue to be made through traditional notice and rulemaking processes. Non-substantive updates are to maintain consistency with the most recent ICD-10 code set.
  • CMS proposes updates to the regulation text to coincide with the assessment changes under PDPM:
    • Initial patient assessment regulation would state: “assessment schedule must include performance of an initial patient assessment no later than the 8th day of post-hospital SNF care”.
  • The Optional Interim Payment Assessment would be included in the regulation.

Stakeholder comments will be accepted until June 18, 2019.

Click here to view the CMS Fact Sheet.

Click here to view the FY 2020 Proposed Rule Pre-publication.