Staring Down the PDPM Barrel!

So, now that you’ve mastered the ins and outs of PDPM, what’s next? You’ve learned the PDPM basics (i.e., changes to the MDS, Case Mix Components, determining the HIPPS code, etc.), but what comes next? Here’s a couple things to think about: Take a look at your current policies and procedures. The way to sustain...

SNF Quality Reporting Program: Non-compliance letters available

CMS has provided notifications to facilities that were determined to be out of compliance with the quality reporting requirements for the Skilled Nursing Facility (SNF) Quality Reporting Program (QRP), which may result in a 2% reduction that will affect their FY 2020 Annual Payment Update (APU). Non-compliance notifications have been sent to the Medicare Administrative...

Proposed Rule Requirements for Long-Term Care Facilities: Changes may be coming!

Proposed Rule Requirements for Long-Term Care Facilities: Changes may be coming! On July 16, 2019, CMS announced a proposed rule, “Medicare & Medicaid Programs; Requirements for Long-Term Care Facilities: Regulatory Provisions to Promote Efficiency and Transparency” (CMS-3347-P) that could bring some welcomed updates to a number of Phase 1 & 2 items as well as...

Five Star Changes: What’s coming next month?

Prepare yourselves! The stars will be realigning next month based on the announcement from CMS this week. Not only will survey results be reinstated (they have been on hold since last November) but there is sure to be more shifting based on changes made to the quality measures and staffing methodologies. The revised Five-Star Technical...

New QRP Detail Available in CASPER Reports!

Earlier this month, CMS added the SNF QRP Provider Threshold Report to the QRP reports available in the QIES system.  Using this report, providers will have more detail and clarity to the status of the required data needed for meeting APU compliance.  If the SNF completes 100% of required data elements on at least 80%...

Bed Safety – Compliance & Reminders

A holistic approach to safety in skilled nursing facilities includes an assessment of resident safety and functioning when in bed.  Residents in long term care are often compromised and frail so to ensure a safe environment, bed safety must be part of an initial and ongoing assessment process. While many hospitals still include use of...

Rising to The Top Deficiency: Abuse Reporting and Investigations

A common struggle SNF administrative teams have is conducting a thorough investigation to rule out abuse. Abuse and investigation citation frequency is steadily climbing above the infamous Infection Prevention & Control that has ranked number one across the nation since the start of our new survey process. If you are struggling in this area, start...

CMS Releases Competency Assessment Toolkit

Last week, the Centers for Medicare & Medicaid Services (CMS) announced upcoming efforts to support better care and outcomes for nursing home residents under the Civil Money Penalty Reinvestment Program (CMPRP). This three-year initiative aims to improve residents’ quality of life by equipping nursing home staff, administrators and stakeholders with technical tools and assistance to...

Phase 3 – Compliance and Ethics

Start Preparing Your Programs Now! Implementing a Compliance and Ethics Program takes time and effort. With Phase 3 of the RoP fast approaching (effective date 11/28/19), providers need to prepare for F895: Compliance and Ethics Program. This is a new regulatory component that requires facilities to have: Written policies and procedures related to compliance and...

Here are Some Answers to Your QRP Questions…

So, your QRP Review and Correct Report shows >80% compliance but CMS is still penalizing you with a 2% reduction in APU? Getting your arms around the QRP data, the Review and Correct Reports and figuring out what needs to be done with the MDSs flagged with incomplete data is not an easy task! A...

Survey Results, coming back to your 5 Star Rating!

Since November 28, 2017, everyone has had a little less survey stress knowing their survey outcomes would not impact their Five Star Rating. Unfortunately, those days are dwindling and it’s time to put this topic back on the table. Details of the survey freeze can be found on S&C memorandum 10-04-NH. CMS has not yet...

CMS Issues RAI Manual Revisions…

We are letting providers know that yesterday CMS finalized the RAI Manual revisions taking effect October 1, 2018. CMS’s most recent MDS changes (version 1.16.0) will significantly impact how they; • assess residents • document • communicate with one another • plan for care. These new requirements effect several sections of the MDS including but not...

Avoid the next QRP 2% Reduction in APU!

Skilled Nursing Facilities not compliant with the Quality Reporting Program (QRP) requirements will be receiving a 2% reduction in their Annual Payment Update (APU) beginning Fiscal Year 2018 and each subsequent rate year moving forward. Facility’s subject to this reduction received their non-compliance letters from the Medicare Administrative Contractors (MAC’s) earlier this month via USPS....

Infection Prevention Control Plan

Preparing for Survey….F800 Infection Prevention and Control Program – Still the Top Deficiency Being Sited  It’s not new news that providers were required to have an Infection Prevention and Control Program (IPCP) by Nov. 28, 2016 (Phase I) and an Antibiotic Stewardship program by Nov. 28, 2017 (Phase 2). What is surprising is that this...

QRP Provider Preview Reports

SNF QRP Public Reporting is coming! What you need to know about your SNF’s QRP Provider Preview Reports. The IMPACT Act of 2014 requires SNF’s to submit Quality Measure data that relates to the care they provide, and to make that information available to the public. The SNF Quality Reporting Program (QRP) data will be...

Five Star and PBJ

Five Star Staffing Rating: The Transition to PBJ Last week, CMS sent out a memorandum to State Survey Directors providing much anticipated information on the transition to Payroll Based Journal (PBJ) Staffing Measures on the Nursing Home Compare Five Star Rating. Facilities have been submitting staffing data electronically through PBJ since July 2016 and many have anxiously...

CMS Revises the SNF ABN

CMS Revises the SNF ABN. Is Your Facility Issuing Proper Medicare Notices? The new survey process requires facilities to provide surveyors a list of ALL Medicare beneficiaries discharged in the last six months within the first 24 hours of survey. Be prepared! It’s time to unravel the mystery and get a jump start on CMS’s newly...

Corporate Compliance: Are you ready?

The NYS OMIG has recently updated their integrity initiatives and work plan for providers and will continue to do so throughout the year in an effort to keep up with the changing Medicaid landscape. One of their major focuses continues to be on collaboration with providers to enhance compliance. Providers are reminded that those subject to...

Therapy Cap Repealed by Congress. Will Your Part B Claims Hold Up in Post-Pay Audit?

How will your Part B therapy claims hold up in audit? Earlier this week, congress passed legislation that permanently repeals the Part B therapy caps. Since 2006, the exception process allowed providers to bill for therapy above cap limits ($2010 annually for PT/ST combined and $2010 annually for OT) with the application of modifiers to...

Where did RCS-1 go?

CMS held an Open Door Forum (ODF) on 3/8/18 leaving providers doubtful that RCS-1 would impact SNF’s this October. A bit if history on this, RCS-1 was initially outlined in a Notice of Proposed Rule Making in May of 2017. The proposal was based on a study CMS had contracted with Acumen to investigate, and...

Emergency Preparedness

Are you ready? As of November 15, 2017, your facility was required to have an Emergency Preparedness program. This CMS mandate required facilities to develop a “comprehensive approach to meeting the health, safety and security needs of their staff and patient population during an emergency or disaster situation. The program must also address how the...

Facility Assessment

Don’t let your Facility Assessment get the best of you, or worse yet, sit on the shelf collecting dust. It can be an essential tool in your tool box when it comes to systems analysis and strategic planning. Let’s face it. There has been no lack of change in the long-term care field over the...

CMS Announces MDS 3.0 Quality Measure (QM) Reports Will Be Unavailable Beginning January 29, 2018

The reports and report package in the MDS 3.0 QM Reports category in the CASPER Reporting application will be unavailable beginning 01/29/2018 while new measures are being added to the reports. The reports that will be unavailable are as follows: MDS 3.0 Facility Characteristics Report MDS 3.0 Facility Level Quality Measure Report MDS 3.0 Monthly...

Kimberly Nelson, RN, BSN

Regional Nurse Consultant

Caryn Riscavage, MS, OTR/L, CLT

Regional Reimbursement & Quality Improvement Consultant