CMS Proposes SNF QRP Changes Under New PDPM

Patient and Nurse

On April 27, rather than announcing the start of the Resident Classification System, Version 1 payment model, the Centers for Medicare & Medicaid Services (CMS) announced a new model called the Patient-Driven Payment Model (PDPM).

The new payment system will take effect on October 1, 2019, leaving a year to study this system, prepare for the changes and learn about the new responsibilities. There are many components to the PDPM, and this article will focus on the Skilled Nursing Facility Quality Reporting Program (SNF QRP) component.

SNFs are already familiar with the QRP, having experienced data gathering and submission, along with having the Quality Improvement and Evaluation System (QIES) Assessment Submission and Processing (ASAP) system notifications and/or a letter (from the CMS and/or the Medicare Administrative Contractor (MAC)) of the annual percentage unit findings for October 1, 2018, if experiencing a penalty. The new listing is found in the new proposed rule—see page 202, Table 39: Quality Measures Currently Adopted for the FY 2020 SNF QRP. There are nine Resident Assessment Instrument Minimum Data Set (RAI/MDS) measures and three claims-based measures already adopted for the fiscal year 2020 SNF QRP. These are as listed:

RAI/MDS Measures

  1. Percent of Residents or Patients with Pressure Ulcers that are New or Worsened (Short Stay) (NQF #0678)
  2. Wording changes only for (1. Percent of Residents or Patients with Pressure Ulcers Above) in Skin Integrity Post-Acute Care (PAC): Pressure Ulcer/Injury Measure Effective 10/1/2018.
  3. Application of Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay) (NQF #0674)
  4. Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function (NQF #2631)
  5. Application of IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients (NQF #2634)
  6. Application of IRF Functional Outcome Measure: Discharge Mobility Score for Medical Rehabilitation Patients (NQF #2636)
  7. Application of IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients (NQF # 2633)
  8. Application of IRF Functional Outcome Measure: Discharge Self-Care Score for Medical Rehabilitation Patients (NQF #2635)
  9. Drug Regimen Review Conducted with Follow-Up for Identified Issues – PAC SNF QRP

Claims-Based Measures

  1. Medicare Spending per Beneficiary (MSPB) – PAC SNF QRP
  2. Discharge to Community – PAC SNF QRP
  3. Potentially Preventable 30-Day Post-Discharge Readmission Measure for SNF QRP

Remember: Even though the quality measure in this proposed rule references a PAC organization other than a SNF, the regulation also is intended for SNFs.

The proposed rule goes on to explain that the CMS also proposes the following future QRP changes:

  1. Adopt an additional factor for evaluating measures for removal from the SNF QRP measure set
  2. Make some changes to the SNF QRP reconsideration requirements
  3. Increase the number of years of data used to calculate the MSPB – PAC SNF QRP and Discharge to Community – PAC SNF QRP measures for purposes of display from one year to two years

The CMS will have some flexibility to alter these quality measures using these three variables without a change in regulation.

SNFs are to begin submitting data for quality measures 2633, 2634, 2635 and 2636 by October 1, 2018. The CMS will publicly display these measures from January 1 to December 31, 2019, for SNFs that meet the minimum number of cases on Nursing Home Compare.

The rule goes on to explain that the submission of this data through the MDS must meet the timing and submission requirements through the QIES. It further explains that a SNF’s “noncompliance” with the SNF QRP requirements will be notified through the QIES ASAP system and U.S. Postal Service and expand the methods to include an email from the MAC. There also will be notification regarding the determination made for a provider’s “request for reconsideration” that will be sent through the QIES ASAP system, a letter sent through the U.S. Postal Service and/or an email from the MAC.

CMS Administrator Seema Verma explains that “publicly sharing this data with the consumer will help the patient make a more informed choice when selecting care service providers for their individual needs.” She also says “the agency supports the Patients over Paperwork Initiative, incentivizing person-centered care and continuing the movement away from paying for volume.”

Read this article by Suzy Harvey to learn about the proposed rule’s new SNF payment model. To see how the proposed rule updates SNF VBP read this article by Bob Lane. Stay tuned for updates as more definitive information concerning the PDPM and other SNF regulatory changes is released. Contact Carol or your trusted BKD advisor if you have questions.

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