Healthcare Update - Changes to the CMS 5-Star Rating

Changes to the Centers for Medicare and Medicaid (“CMS”) Five-Star Quality Rating System will take effect in April 2019. These changes aim at improving the comparability and transparency of quality in skilled nursing facilities (“SNF”) for the consumer. The Nursing Home Compare website reports ratings on three categories (health inspections, staffing, and quality measures) and then provides an overall rating. A change to any single category may impact the overall rating. A summary of the significant changes are as follows.

Health inspections

What’s new - CMS temporarily froze the impact on this rating, due to the implementation of new survey requirements. Now that all facilities have gone through an annual survey under the new requirements, the rating for this category will be impacted by the three most recent annual surveys and the most recent 36 months of complaint surveys. Points are assigned to individual deficiencies based on their scope and severity, starting with level “D” deficiencies. The most recent surveys are weighted heavier than older surveys. Since there is variability among states in the survey process, facilities are ranked based on other facilities within their state. Ratings will be recalculated when the facility has a new survey and their older surveys age out.

How to prepare – Make sure your team is trained and prepared for the new survey process. Set up routine internal inspections and share results with your staff. Conduct periodic mock surveys to identify areas needing improvement. Formalize procedures and policies for staff to follow and be accountable for.

Staffing

What’s new – Studies have found a link between the level of RN hours per patient, per day, to quality of care outcomes, therefore, more emphasis has been placed on RN-staffing statistics. A facility will receive a one-star rating if the facility has four or more days (previously, seven or more days) in a quarter with no RN hours.

How to prepare – Since the rating is calculated based on the hours submitted through the quarterly Payroll-Based Journal (PBJ), it is important to review how this information is reported before it is submitted. Ensure that the appropriate hours and personnel are being coded to the correct PBJ job code.

Quality measures

What’s new – New measures will be added to look at long-term stays and short-term stays, separately. In addition, quality measure thresholds will continuously increase every six months to encourage facilities to improve their statistics.

How to prepare – Develop benchmarks that are in line with industry standards and include inflation factors to anticipate the increases in the thresholds. Develop a reporting process to periodically monitor statistics against the benchmarks. In addition, ensure all data is accurately captured in the MDS before it is submitted.

If you would like further information and assistance, please contact a Citrin Cooperman Healthcare Practice team member at healthcare@citrincooperman.com.