The Centers for Medicare & Medicaid Services (CMS) recently sent noncompliance notifications to skilled nursing facilities (SNF) concerning Quality Reporting Program (QRP) requirements. These requirements will affect SNF providers starting October 1, 2017, for fiscal year (FY) 2018 Annual Payment Update (APU).
The IMPACT Act of 2014 mandated CMS to establish quality measures for “like” data across multiple post-acute care venues. Beginning for SNFs with FY 2018 and each year thereafter, “the Secretary shall reduce the market basket update (also known as the Annual Payment Update, or APU) by 2 percentage points for any SNF that does not comply with the quality data submission requirements with respect to that FY.” For FY 2018, the data period used to determine compliance was October 1, 2016, through December 31, 2016. All “skilled admissions” to a SNF starting October 1, 2016, and discharged up to and including December 31, 2016, would be data collected to determine compliance. Providers must have submitted all required data to calculate SNF-QRP measures on at least 80 percent of the minimum data set (MDS) assessments submitted to meet the requirements. Examples of the measures include:
- National Quality Forum (NQF) #0678: Percent of residents or patients with pressure ulcers that are new or worsened (short stay)
- NQF #0674: Application of percent of residents experiencing one or more falls with major injury (long stay)
- NQF #2631: Application of percent of long-term care hospital patients with an admission and discharge functional assessment and a care plan that addresses function
CMS has corresponded year round through various venues concerning start and end of data collection, when all data “must” be submitted, and offered time for “corrections” of submitted data, going so far as to extend that date by one month. Now the notifications that have landed in some facilities’ Quality Improvement Evaluation Systems (QIES) will inform providers they didn’t meet the 80 percent threshold for the MDS assessment requirements submitted.
You need to request all information out of the Certification and Survey Provider Enhanced Reports reporting system from your MDS coordinator or person(s) in the facility having the necessary passwords to get into the QIES. CMS also has indicated it mailed this information to providers on July 14, 2017.
If after reviewing your data you feel the determination of noncompliance was made in error, you may submit a request for “reconsideration” to CMS through email no later than August 13, 2017, by 11:59 p.m. PST. Directions for this reconsideration request can be found in the letter and also on the CMS website.