As a reminder, public reporting of skilled nursing facility (SNF) provider performance on the quality measures is now available on the Nursing Home Compare website run by the Centers for Medicare and Medicaid Services (CMS). Specifically, CMS has posted the inaugural release of SNF QRP Quality Reporting Program (QRP) data as noted in CMS’ fact sheet released on October 24, 2018.
Five SNF QRP measures are now available on Nursing Home Compare, including three assessment-based and two claims-based measures. The five measures are:
- Percent of Residents or Patients in a SNF that develop new or worsened pressure ulcers.
- Percentage of residents or patients whose activities of daily living and thinking skills were assessed and related goals were included in their treatment plan.
- Percentage of SNF patients who experience one or more falls with major injury during their SNF stay.
- Medicare Spending Per Beneficiary (MSPB) for patients in SNFs.
- Rate of successful return to home or community from an SNF.
A sixth quality measure, Potentially Preventable 30-Day Post-Discharge Readmissions, has yet to be published as CMS seeks additional time to determine if modifications are needed. CMS will not post reportable data for this measure during this testing phase, to include each SNF’s performance, as well as the national rate.
Want to be a PDPM Winner?
As you all know, the Patient Driven Payment Model (PDPM) reimbursement method begins October 1, 2018. Many providers are concerned about the impact on the rates they are currently receiving and how they can come out on top under PDPM. Specifically, under the Patient-Driven Payment Model (PDPM), the clinical condition of a patient (rather than the number of therapy minutes that patient receives) will drive Medicare reimbursement under PDPM. Most of that clinical information is captured on the Minimum Data Set (MDS).
Under the current Resource Utilization Group (RUG) system, however, operators may not be recording all the necessary MDS data that will soon be vital to reimbursements. Unfortunately, it is common practice under the current RUGs system to focus on the rehab areas of the MDS assessment while the majority of other areas do not get much attention. In order to come out on the winning side, skilled nursing facilities (SNFs) must make sure they are capturing all the patient characteristics appropriately on the MDS. It is going to be imperative under PDPM that the entire MDS is correct because therapy days and minutes aren’t going to drive the payment. Providers should do the following now to maximize their potential under PDPM:
- Establish a dedicated team with specific, focused roles for individuals and with ICD-10 coding as the first area of priority. This places the patient in one of those 10 clinical categories, which starts the process of determining their overall reimbursement. It is very important under PDPM to receive accurate information from hospitals. Providers need to educate their local hospitals now on the information they would need from them in October.
- The very next priority should be the MDS, because while ICD-10 coding will drive the primary diagnosis and thus the first grouping under PDPM, the MDS then starts to determine the case mix adjustments for the various components of nursing, physical therapy, occupational therapy, speech therapy, and non-therapy ancillaries (NTAs).
- “Start coding as if your reimbursement depended on it.” Because it does. The key here will be assessing your processes for getting this information to the MDS coordinator and his or her backup, from the source of origin. Most of this information is going to come from nursing and the therapy team, some electronically, some manually. Whatever systems are in place now may need to be supplemented to make sure this information makes it to that critical, five-day MDS timely and accurately.
The next area of care that will need focus is therapy, with a particular focus toward developing clinical pathways. A SNF must identify the five primary diagnoses it is currently treating and focus on the communication between nursing, therapy and the physicians or nurse practitioners. SNFs must also designate employees to overhaul in-house educational materials and technology systems.
