United States

Senior Living Health Care Connection: Quality Reporting program

INSIGHT ARTICLE  | 

This is the final installment in a series of three alerts highlighting the Prospective Payment System (PPS) and Consolidated Billing for Skilled Nursing Facilities (SNFs) for FY 2016 Final Rule.

Topics highlighted in the series include:

  1. Staffing data collection
  2. SNF Value-Based Purchasing program
  3. SNF Quality Reporting program

Quality Reporting program

The National Quality Forum released the measures under consideration for 2016 for the health care industry, which includes SNFs. While these are being considered by the Centers for Medicare & Medicaid Services (CMS),  it’s important to understand the quality measures found in the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act), which has two focuses:

  1. The implementation of a quality reporting program for SNFs. The SNF Quality Reporting program (SNF QRP) also includes home health agencies (HHAs), long term care hospitals (LTCHs) and inpatient rehabilitation facilities (IRFs).
  2. Beginning in FY 2018, SNFs that fail to submit the required data to CMS will have their annual updates reduced by two percentage points.

For FY 2018 payment determination, providers will be required to submit data for Part A residents admitted on and after Oct. 1, 2016, and discharged from the SNF up to and including Dec. 31, 2016. Officials from CMS noted that the data submission deadline is May 15, 2017.

Time frame for collecting data:

  • Oct. 1, 2016, through Dec. 31, 2016

Data submission deadline:

  • May 15, 2017

The Quality Reporting measures have three domains:

  1. Skin integrity
  2. Incidence of falls with major injury
  3. Functional status

Skin integrity

  • Percent of residents or patients with pressure ulcers that are new or worsened (short stay)
    • Includes stage 2 through 4 (unstageable) pressure ulcers that are new or worsened
    • Looks at prior minimum data set (MDS) with no or lesser stage
    • MDS sections:
      • Stage 2 (M0800A) > 0, or
      • Stage 3 (M0800B) > 0, or
      • Stage 4 (M0800C) > 0
  • Assessments may be:
    • Discharge, PPS 5-day, 14-day, 30-day, 60-day, 90-day, SNF PPS Part A discharge assessment, or
    • Omnibus Budget Reconciliation Act (OBRA) admission, quarterly, annual or significant change assessments
  • Risk adjustments are included in the measure:
    • Level of function
    • Bowel incontinence
    • Diabetes or peripheral vascular disease (PVD)
    • Low body mass index

Incidence of falls with major injury

  • Percent of residents experiencing one or more falls with major injury (long-term stay)
    • Major injury is defined as bone fractures, joint dislocations, closed head injuries with altered consciousness or subdural hematoma
  • Assessments include:
    • SNF PPS Part A discharge assessment
    • A stay is defined as the time period from resident admission or reentry to the facility (identified by a five-day PPS assessment) to discharge, which may be an OBRA discharge or a SNF PPS Part A discharge
    • This measure is not risk-adjusted

Functional status

  • This measure requires the collection of standardized functional assessment data across SNFs, long term care hospitals (LTCHs), and inpatient rehabilitation facilities (IRFs), using standardized data items
  • Would establish a common language for patient or resident functioning
  • May facilitate communication and care coordination as patients or residents transition from one type of provider to another
  • Items:
    • Self-care items
      • Eating - The ability to use suitable utensils to bring food to the mouth and swallow food once the meal is presented on a table or tray
      • Oral hygiene - The ability to use suitable items to clean teeth or dentures if applicable
      • Toileting hygiene - The ability to maintain perineal hygiene, adjust clothes before and after using the toilet, commode, bedpan or urinal
    • Mobility items
      • Sit to lying - The ability to move from sitting on side of bed to lying flat on the bed
      • Lying to sitting on side of bed - The ability to safely move from lying on the back to sitting on the side of the bed, with feet flat on the floor and with no back support
      • Sit to stand -The ability to safely come to a standing position from sitting in a chair or on the side of the bed
      • Chair or bed to chair transfer - The ability to safely transfer to and from a bed to a chair (or wheelchair)
      • Toilet transfer - The ability to safely get on and off a toilet or commode
    • Mobility items  for residents who are walking
      • Walk 50 feet with two turns - Once standing, the ability to walk at least 50 feet and make two turns
      • Walk 150 feet - Once standing, the ability to walk at least 150 feet in a corridor or similar space
    • Mobility items  for residents who use a wheelchair
      • Wheel 50 feet with two turns - Once seated in wheelchair or scooter; the ability to wheel at least 50 feet and make two turns
        • Indicate manual or motorized wheelchair or scooter
      • Wheel 150 feet; once seated in wheelchair or scooter, the ability to wheel at least 150 feet in a corridor or similar space
        • Indicate manual or motorized wheelchair or scooter
    • Rating scale
      • Independent - No assistance
      • Setup or cleanup assistance – Helper sets up or cleans up
      • Supervision or touching assistance – Verbal cues or touching or steadying
      • Partial or moderate assist – Helper does less than half
      • Substantial/maximal assist – Helper does more than half
      • Dependent – Helper does all the effort or requires two or more helpers

The MDS effective for Oct. 1, 2016, contains the changes to allow for the care data collection. To learn more, go to https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/NHQIMDS30TechnicalInformation.html, right click and choose “Open hyperlink.” You can view the Oct. 1, 2016, MDS at the bottom of the page.

To view the Final Rule go to https://www.federalregister.gov/articles/2015/08/04/2015-18950/medicare-program-prospective-payment-system-and-consolidated-billing-for-skilled-nursing-facilities, right click and choose “open hyperlink.”

For more information, contact Joan McCarthy at 312.634.3479.

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