On September 20, 2023, the Centers for Medicare and Medicaid Services (CMS) released QSO-23-21-NH with the subject updates to Nursing Home Care Compare staffing and quality measures (QMs). An important note about the memo is the Payroll Based Journal (PBJ) changes that take effect April 1, 2024.
The changes are the result of CMS updating the staffing level case-mix methodology, which were necessary because of the MDS changes. These changec also mandates a penalty to providers who fail to submit staffing data or submit erroneous data. CMS is trying to incentivize providers to submit accurate data, and therefore penalize the providers who fail to submit staffing data or submit erroneous data. The provider who fails to submit data or submits erroneous data will receive the lowest score possible for corresponding staffing turnover measures.
Currently, CMS adjusts the nurse staffing measures using a case-mix methodology that is based on MDS items from the previous Medicare Prospective Payment System. CMS also uses some of these MDS items to risk-adjust some of the QMs. In October 2023, the items in the MDS Section G were removed and replaced by new Section GG items. This requires CMS to change the staffing case-mix adjustment method.
The staffing measures are based on nursing home staffing levels and staff turnover. Ratings for the staffing domain are based on six measures. This includes three nurse staffing level measures (hours per resident per day) and three measures of staff turnover. The staffing measures are derived from data submitted each quarter through the PBJ System, along with daily resident census derived from Minimum Data Set, Version 3.0 (MDS 3.0) assessments. The nurse staffing level measures are case-mix adjusted based on the distribution of MDS 3.0 assessments by Resource Utilization Groups, version IV (RUG-IV groups) and cover a single quarter. The turnover measures use six consecutive quarters of PBJ data to define annual turnover for nursing staff and administrators.
Beginning in April 2024, CMS will freeze the staffing measures for three months while the transition is made. In July 2024, CMS will post nursing home staffing measures based on the new PDPM methodology.
Staffing in nursing homes has a substantial impact on the quality of care and outcomes that residents experience. Nursing homes receive points based on how they perform on each staffing measure; these points are used to assign star ratings. Currently, nursing homes that fail to submit staffing data or submit erroneous data for staffing levels receive a one-star staffing rating for the quarter in which the data are reported. However, nursing homes that fail to submit data to calculate staff turnover have their staff turnover measures excluded from the staffing rating calculation. Thus, there is no impact on their score. Posting accurate and complete staffing data is important to CMS’ commitment to transparency. Therefore, to further incentivize facilities to submit accurate staffing data, beginning in April 2024, CMS will revise the staffing rating methodology so providers that fail to submit staffing data or submit erroneous data receive the lowest score possible for corresponding staff turnover measures for six quarters.
Each facility should review the information on submitting the turnover data to ensure it is being done correctly. The staffing data starts on page 15 of the Nursing Home Care Compare Five Star Technical Users’ Guide.