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

Now that routine surveys are beginning to take place in most states, it is important that vigilant infection prevention and control practices do not take a backseat to other survey-ready quality assurance activities. Notably, HHS announced a $2.0 billion payment incentive program (VBP) with $500 million per month for four months Sept. -December 2020 paid based on SNF performance in managing the rate of COVID-19 infections each month and the COVID-19 mortality rate for the month as compared to other facilities with similar community infection rates. Details are forthcoming on the specific formula to be used for distribution of funds, but it is anticipated that a facility may be excluded from receiving a portion of these funds if performing significantly worse than peers on these measures.

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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.

SNF PEPPER summarizes data statistics which are obtained from paid SNF Medicare UB-04 Claims for SNF episodes of care that end in the most recent three federal fiscal years (the federal fiscal year spans October 1-September 30). The current version of PEPPER now available reviews episodes of care through quarter 4 of FY2019 including statistics for 2017, 2018, and 2019. SNFs are compared to other SNFS in three comparison groups: nation, MAC, and state. These comparisons enable a SNF to determine if their results differ from other SNFs and whether it is an outlier and/or at risk for improper payments.

Target Area Updates

The following RUGs focused target areas will be phased out for FY2020 as a result of PDPM: Therapy RUGS with High ADL, Nontherapy RUGs with High ADL, Change of Therapy Assessment, & Ultrahigh Therapy RUGS. These target areas are included in the current FY2019 report along with the target areas: 20-day episodes of care, 90+ day episodes of care, and a new target area: 3-5 day readmissions which reviews readmissions to the SNF following a 3-5 calendar day gap. Please note this target area will not reflect claims until FY2020 and is intended to give providers information on readmission practices before and after PDPM implementation in order to assess the level to which facilities “may attempt to circumvent interrupted stay rules.”

Please click here for a table of target area definitions and suggestions.

The July 2020 Nursing Home Compare refresh, including quality measure results based on SNF QRP data submitted to CMS, is now available.

The following SNF QRP measures will displayed on NH Compare during the July 2020 refresh.

  1. Application of Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay). Q4 2018 – Q3 2019 (10/01/18 – 09/30/19)
  2. Application of Percent of Long-Term Care Hospital (LTCH) Patients With an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function . Q4 2018 – Q3 2019 (10/01/18 – 09/30/19)
  3. Medicare Spending Per Beneficiary-PAC SNF QRP. Q4 2016 and Q3 2018(10/01/16 – 9/30/18)
  4. Discharge to Community-PAC SNF QRP. Q4 2016 and Q3 2018(10/01/16 – 9/30/18)
  5. Potentially Preventable 30-Day Post-Discharge Readmission Measure – SNF QRP. Q4 2016 and Q3 2018(10/01/16 – 9/30/18)

Visit the NH Compare website to view your updated quality data.

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.