CMS to End Certain COVID-19 Waivers

CMS TO END CERTAIN COVID-19 WAIVERS

BACKGROUND
The Center for Medicare and Medicaid Services released a memorandum on April 7th  to state agencies announcing the ending of specific Public Health Emergency (PHE) waivers in two different time frames: May 7th and June 7th.

WHAT YOU NEED TO KNOW
The following waivers related to SNF’s will end on May 7th:

  • Resident Groups: This waiver permitted the facility to restrict in-person meetings during the PHE
  • Physician Visits: CMS waived the requirement for physicians and non-physician practitioners to perform in-person visits for nursing home residents and allow visits to be conducted, as appropriate, via telehealth options
  • Physician Delegation of Tasks in SNFs: CMS waived the requirement that prevents a physician from delegating a task when the regulations specify that the physician must perform it personally
  • Quality Assurance & Performance Improvement (QAPI): CMS modified certain requirements which require long-term care facilities to develop, implement, evaluate, and maintain an effective, comprehensive, data-driven QAPI program
  • Detailed Information Sharing for Discharge Planning for LTC Facilities: CMS modified the requirement that LTC facilities are to assist residents and their representatives in selecting a post-acute care provider
  • Medical Records: CMS modified the requirement which requires long-term care (LTC) facilities to provide a resident a copy of their records within two working days

The following waivers related to SNF’s will end on June 7th:

  • Physical Environment: CMS waived requirements to allow for a non-SNF building to be temporarily certified and available for use by a SNF in the event there were needs for isolation processes for COVID-19 positive residents
  • Facility & Medical Equipment Inspection, Testing & Maintenance: CMS waived ITM requirements for facility and medical equipment to reduce exposure to COVID-19
  • Life Safety Code (LSC) and Health Care Facilities Code (HCFC) ITM: CMS waived ITM required by the LSC and HCFC, with specified exceptions, which permitted facilities to adjust scheduled ITM frequencies and activities
  • Outside Windows and Doors: CMS waived the requirement to have an outside window or outside door in every sleeping room. This permitted spaces not normally used for patient care to be utilized for patient care and quarantine.
  • Paid Feeding Assistants for LTC Facilities: CMS modified the requirements regarding required training of paid feeding assistants to allow that training can be a minimum of one hour in length
  • In-Service Training for LTC Facilities: CMS modified the nurse aide training requirements for SNFs, which required the nursing assistant to receive at least 12 hours of in-service training annually
  • Training and Certification of Nurse Aides: CMS waived the requirements which require that a SNF  may not employ anyone for longer than four months unless they met the training and certification requirements

Source:  CMS’ Memorandum: QSO-22-15-NH & NLTC & LSC


Preferred Therapy Solutions continues to provide vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported by compliance and regulatory requirements that are necessary for a thorough understanding of practices and procedures. If you have any questions, please contact Maria Maggi, Vice President of Quality, Outcomes, and Compliance: mmaggi@preftherapy.com

 

EDUCATIONAL WEBINAR: FY 2023 SNF PPS Proposed Rule – What’s Ahead for PDPM, QRP & VBP!

The FY 2023 Proposed Rule is out and CMS is following through on the recalibration of PDPM, adding new measures for quality and value-based care, and building upon the Biden-Harris Administration’s commitment to advance health equity, drive person-centered care and promote sustainability of the program. Register below to join this informative webinar.


MAY 17TH | 12:30 PM | CLICK HERE TO REGISTER
FY 2023 SNF PPS Proposed Rule: What’s Ahead for PDPM, QRP & VBP!

Attendees of this session will gain insight on:

  • Understand the proposed changes to Medicare PPS reimbursement and quality reporting
  • Identify the potential impact of the proposed changes and begin strategic planning initiatives
  • Learn how to submit comments and provide feedback to CMS on the proposed changes

This program has been approved for Continuing Education for 0.50 total participant hours by NAB/NCERS—Approval #20230516-0.50-A83943-DL

CMS Releases FY 2023 Proposed Rule

BACKGROUND

The Centers for Medicare and Medicaid Services (CMS) are legally required to update the Medicare payment rates and quality programs on an annual basis. Each April, CMS publishes a proposed rule for the upcoming fiscal year (FY) and opens a comment period for stakeholders to review and provide comments to CMS before releasing the final rule.

WHAT YOU NEED TO KNOW

On April 11th CMS issued proposed rule CMS-1765-P for FY 2023. This proposed rule contains many areas of importance and significance for SNF providers specifically as it relates to payment, quality, staffing, and more.

Preferred Therapy Solutions is thoroughly reviewing the proposed rule and has planned an in-depth webinar for May 17th, which has already received program approval from the National Association of Long Term Care Administrators Board (NAB).

Key elements of the proposed rule include:

  • PAYMENT UPDATES
    CMS estimates the aggregate impact of payment policies would result in a decrease of approximately $320 million in Medicare Part A payments to SNFs in FY 2023
  • The actual payment update for FY 2023 is a 3.9% increase based on SNF market basket and forecast error adjustments but this increase is offset by a 4.6% decrease in SNF PPS rates as a result of a proposed recalibrated parity adjustment
  • An additional $186 million in reductions is estimated based on the SNF VBP program

UPDATED BASE RATES FOR PDPM COMPONENTS

PATIENT DRIVEN PAYMENT MODEL

  •  Recalibrating the PDPM Parity Adjustment
    • The purpose of the parity adjustment is to ensure budget neutrality between RUG-IV and PDPM
    • In last year’s proposed and final rules, CMS shared that the transition from RUG-IV to PDPM was not budget neutral with a 5% increase in Medicare Part A payments to SNFs under PDPM. They sought feedback from stakeholders regarding how and when to recalibrate the PDPM parity adjustment, but never proposed an actual parity adjustment
    • In this year’s proposed rule, CMS improved its methodology to determine the necessary parity adjustment and is proposing a 4.6% decrease in PDPM payments
    • CMS is proposing to accomplish the parity adjustment by recalibrating all PDPM CMI’s equally (PT, OT, SLP, Nursing, and NTA)
    • CMS is proposing to implement the entire recalibration all at once, without delay or phase-in
  • CMS is proposing several changes to the PDPM ICD-10 code mappings and lists

SNF QUALITY REPORTING PROGRAM (QRP)

  • CMS is proposing to adopt one new quality measure to become part of the SNF QRP for FY 2025: Influenza Vaccination Coverage among Healthcare Personnel (HCP) measure
  • CMS is proposing to revise the compliance dates for specific SNF QRP requirements
  • CMS is seeking comments on 3 subjects
    • Future measures for SNF QRP
    • Overarching principles for measuring equity and healthcare disparities
    • Inclusion of CoreQ: Short Stay Discharge Measure in the SNF QRP

SNF VALUE-BASED PURCHASING (VBP) PROGRAM

  • CMS is proposing to suppress the SNF 30-day All-Cause Readmission Measure for the FY 2023 SNF VBP due to the COVID-19 PHE
    • In order to maintain compliance with the statutory requirements of the SNF VBP program, CMS is proposing to do the same process implemented last year as it relates to the SNF VBP
      • CMS will continue to withhold 2% of Medicare Part A FFS payments per statute
      • CMS will “award” SNF’s 60% of the withhold, resulting in a 1.2% payback
      • The proposal will result in 0.8% decrease in Medicare Part A FFS payments for all SNF’s except those that are subject to the Low Volume Adjustment policy
  • CMS is proposing to add two new measures to the FY 2026 SNF VBP and one new measure to the FY 2027 SNF VBP
    • FY 2026: addition of SNF Healthcare-Associated Infections Requiring Hospitalization and Total Nursing Hours per Resident Day measures
    • FY 2027: addition of Discharge to Community – Post-Acute Care Measure for SNFs
  • CMS is seeking feedback on the following for the SNF VBP
    • Implementing a Nursing Home Staff Turnover measure
    • Scoring methodology and how it converts to incentive payments
    • Incorporating adjustments related to health equity

Finally, Preferred Therapy Solutions will be submitting comments and feedback to CMS to advocate for therapy services, SNF providers, and most importantly, the residents we are privileged to serve. We encourage all providers to do the same!

NAB APPROVED WEBINAR
Join our webinar on May 17th to learn more about the proposed rule and how to advocate for our industry and patients. Details and links to join this webinar will be provided at a later date.

Preferred Therapy Solutions continues to provide vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported by compliance and regulatory requirements that are necessary for a thorough understanding of practices and procedures. If you have any questions, please contact Matt Nash, Vice President of Strategy and Business Development: mnash@preftherapy.com

WHAT YOU NEED TO KNOW ABOUT OSHA INSPECTIONS

BACKGROUND

On March 7th, the Occupational Safety and Health Administration (OSHA) announced highly focused inspections directed at hospitals and skilled nursing care facilities that treat or handle COVID-19 patients. The timeframe will be from March 9,- June 9, 2022.

WHAT YOU NEED TO KNOW

OSHA’s goal is to expand its presence to ensure the following:

  • Continued mitigation to control the spread of COVID-19 and future variants
  • Compliance with infection control policies and standards, including appropriate fit testing and required documentation for the use of N95 masks
  • Protect the health and safety of healthcare workers at heightened risk for contracting the virus
  • Complete follow-up inspections at sites that were previously issued citations

The Department of Labor’s memorandum on OSHA’s inspections can be found here.

Preferred Therapy Solutions continues to provide vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported with compliance and regulatory requirements that are necessary for a thorough understanding of practices and procedures. If you have any questions, please contact Maria Maggi, Vice President of Quality, Outcomes, and Compliance at mmaggi@preftherapy.com

BREAKING NEWS

CMS Mandates Strict Testing of COVID-19 for Nursing Home Staff. Fines up to $8,000 for Non-compliance.

To our valued customers:   Yesterday, The Centers for Medicare & Medicaid Services (CMS) implemented new regulatory changes for Skilled Nursing Facilities (SNF); all SNF’s must regularly test their personnel for the COVID-19 virus and are required to offer testing to their residents. As part of this mandate, facilities that use point-of-care COVID-19 testing devices are required to report their diagnostic test results as part of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).

CMS Administrator, Seema Verma stated: “Reporting of test results and other data are vitally important tools for controlling the spread of the virus and give providers on the front lines what they need to fight it.”  

Skilled Nursing Facilities that do not act in accordance with this new rule will be cited and fined for noncompliance and may face fines based on the severity of the violation. Penalties of $400 per day, or over $8,000 for an instance of noncompliance. To learn more about the new rule, please visit the CMS website at https://go.cms.gov/3gvFD9f

Preferred Therapy Solutions continues to provide its partners with vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported with compliance and regulatory requirements that are necessary for a thorough understanding on practices and procedures. If you have any questions, please contact  Maria Maggi, Vice President of Quality, Outcomes, and Compliance at: mmaggi@preftherapy.com

Source: https://www.cms.gov/

CMS Releases FY 2021 Proposed Rule: SNF’s In-Line for 2.3% Payment Increase

BACKGROUND
The Centers for Medicare and Medicaid Services (CMS) are legally required to update the Medicare payment rates and quality programs on an annual basis. Each April, CMS publishes a proposed rule for the upcoming fiscal year and opens a comment period for stakeholders to review and provide comments before CMS releases the final rule.

WHAT YOU NEED TO KNOW
On April 10th CMS issued proposed rule (CMS-1737-P) for FY 2021. CMS recognizes that the healthcare industry is focused on the COVID-19 public health emergency, and as such, this proposed rule contains statutorily required payment updates as well as proposals that reduce provider burden which may help in their COVID-19 response. 

Key elements of the proposed rule include:

  • A net market basket increase of 2.3% resulting in an increase of $784 million in Medicare payments for SNF providers
    > Please refer to the table below for Unadjusted Federal Per Diem
    Rates by PDPM Component
  • Proposal to adopt the revised Office of Management and Budget (OMB) statistical area delineations with a 5% cap on wage index decreases from FY 2020 to FY 2021
  • Updates to the ICD-10 code mappings with additional codes/diagnosis now qualifying for “May be Eligible for Non-Orthopedic Surgery Category” or “May be Eligible for One of the Two Orthopedic Surgery Categories”
    > Additional substantive changes to clinical category as well as NTA
    mappings are also proposed that impact only a few diagnosis/ICD-10
    codes
  • CMS acknowledged it continues to monitor the impact of PDPM on patient outcomes and program payments but stated it would be premature to release any information or make changes to case-mix weights with the limited data available
    > CMS did state they may consider adjustments to case-mix weights in
    future rulemaking in order to maintain budget neutrality
  • Proposals related to the Skilled Nursing Facility Value Based Purchasing Program (SNF VBP)
    > Apply a 30-day Phase One Review and Correction Deadline to the
    baseline period
    > Estimated FY 2023 SNF VBP Program Performance Standards
    > > Achievement Threshold: 0.79025 (readmission rate of 21.0%)
    > > Benchmark: 0.82917 (readmission rate of 17.1%)
  • No changes to the Skilled Nursing Facility Quality Reporting Program (SNF QRP) were proposed

Preferred Therapy Solutions continues to provide its partners with vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported with compliance and regulatory requirements that are necessary for a thorough understanding of practices and procedures. If you have any questions, please contact Matt Nash, Vice President of Strategic Development at mnash@preftherapy.com

SOURCE: CMS



















CMS Updates PDPM-ICD-10 Mappings for COVID-19

BACKGROUND
The Centers for Medicare & Medicaid Services (CMS) has the authority to update the list of ICD-10-CM codes used for capturing various payment components under PDPM. CMS has exercised this authority and has released an update of the PDPM DLL Package (V1.0004 FINAL). This update adds support for the new ICD-10-CM code for Coronavirus, U07.1, which takes effect April 1, 2020. 

WHAT YOU NEED TO KNOW
The new ICD-10-CM code for Coronavirus, U07.1, has been added to the list of acceptable codes that can be used in section I0020b of the MDS to indicate the resident’s primary reason for the Medicare Part A stay. Of significance for skilled nursing facility providers and MDS coordinators, the Coronavirus ICD-10-CM U07.1 will impact the case-mix adjusted components of PDPM as follows:

·    PT/OT: Qualify a patient for the Medical Management clinical category
·    SLP: Qualify a patient for the Non-Neurologic clinical category 
·    Nursing: The diagnosis itself does not have a direct impact to qualify a patient for any of the nursing case-mix groups, but the clinical characteristics and associated services related to a patient with Coronavirus will certainly influence nursing capture
·    NTA: The diagnosis does not currently qualify for any NTA points or additional NTA reimbursement

The Coronavirus ICD-10-CM code can be used on MDS’ with a target date of 04/01/2020 or later.
 
To download the ZIP file on the CMS updated FY2020 PDPM IDC-10 Mappings click here.
 
Preferred Therapy Solutions continues to provide its partners with vital information that may impact rehabilitation management, reimbursement policies, and clinical programs, supported with compliance and regulatory requirements that are necessary for a thorough understanding on practices and procedures. If you have any questions, please contact Matt Nash, Vice President of Strategic Development at: mnash@preftherapy.com
 
SOURCE: CMS

*TIME SENSITIVE* CMS HOSTING NATIONAL PROVIDER CALL Learn CMS’ Review and Corrections Process for VBP before it’s too late!

Phase One Review and Corrections Call — March 20th

Background
The SNF Value Based Program measure, Skilled Nursing Facility 30-Day All-Cause Readmission Measure (SNFRM) estimates the risk-standardized rate of all-cause, unplanned hospital readmissions of Medicare SNF beneficiaries within 30 days of discharge from their prior acute hospitalization. Incentive payments based on this measure began in Oct 2018 for FY 2019. It is based on how a facility scores when comparing their baseline period versus their performance period, and utilizes a performance and achievement score.

Phase One is an opportunity for SNFs to review and submit corrections to the quality and facility-level information that will be made publicly available. The deadline for correction submission is April 1, 2019.

What you need to know
On Wednesday, March 20, 2019, the Medicare Learning Network will host a National Provider Call entitled, “Skilled Nursing Facility (SNF) Value-Based Purchasing (VBP) Program: Phase One Review and Corrections call.” During this call, participants will learn about the SNF VBP Program Review and Corrections process and receive answers to frequently asked questions about Phase One of the process.

There will also be a question and answer session following the presentation; however, attendees may email questions in advance to SNFVBPInquiries@cms.hhs.gov with “SNF VBP Mar 20 NPC” in the subject line.

To register for this MLN event, follow the instructions provided in the following link: https://blh.ier.intercall.com/

Courtesy of NASL

If you have any questions, please contact:
Maria Maggi, Vice President of Compliance mmaggi@preftherapy.com

*TIME SENSITIVE* SNF Provider Preview Reports Now Available

REVIEW BEFORE DATA MADE PUBLIC

Background
Prior to the release of SNF QRP data on Nursing Home Compare, SNFs have the opportunity to review their quality measure results during a 30-day preview period. Providers have until March 4, 2019, to review QRP data prior to the April 2019 Nursing Home Compare site refresh, during which this data will be publicly displayed. SNFs are encouraged to review the SNF Provider Preview Report, issued quarterly by CMS and accessed through the CASPER system. Instructions on how to access these reports are located here.

Corrections to the underlying data will not be permitted during this time, however, providers can request a CMS review of their data during the preview period if they believe the quality measure scores that are displayed within their Preview Reports are inaccurate.

What you need to know

The data contained within the Preview Reports is based on quality data submitted by SNFs during the following quarterly time frames:

  • Quarter 3 – 2017 to Quarter 2 – 2018 data
    • Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay)
    • Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short Stay)
    • Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function
  • Quarter 4 – 2016 to Quarter 3 – 2017 data 
    • Medicare Spending Per Beneficiary – Post-Acute Care (PAC) Skilled Nursing Facility Measure
    • Discharge to Community- Post Acute Care (PAC) Skilled Nursing Facility (SNF) Quality Reporting Program (QRP)

As we stated in our last alert, CMS announced in October 2018 that it will not publish the 6th previously posted quality measure, Potentially Preventable 30-Day Post-Discharge Readmissions, at this time. According to CMS, additional time will allow for more testing to determine if modifications to the measure and method of displaying it are needed. This additional testing will ensure that the future publicly reported measure is thoroughly evaluated so Nursing Home Compare users have an accurate picture of provider quality. While CMS conducts this additional testing, the agency will not post reportable data for this measure, including each SNF’s performance, as well as the national rate. To view the updated quality data, please visit the Nursing Home Compare website.

Courtesy of NASL

If you have any questions, please contact Maria Maggi, Vice President of Compliance mmaggi@preftherapy.com.