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Open Door Forum: SNF Quality Reporting Program Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum FY 2016 SNF PPS NPRM Tara McMullen, PhD Division of Chronic and Post Acute Care May 14, 2015

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Page 1: Open Door Forum: SNF Quality Reporting Program Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum FY 2016 SNF PPS NPRM Tara McMullen,

Open Door Forum:SNF Quality Reporting Program

Open Door Forum:SNF Quality Reporting Program

Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum

FY 2016 SNF PPS NPRM

Tara McMullen, PhDDivision of Chronic and Post Acute CareMay 14, 2015

Page 2: Open Door Forum: SNF Quality Reporting Program Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum FY 2016 SNF PPS NPRM Tara McMullen,

• The IMPACT Act of 2014 sets forth the requirements for Skilled Nursing Facilities (SNFs) to submit data to CMS.

• Beginning FY 2018, providers [SNFs] that do not submit required quality reporting data to CMS will have their annual update reduced by 2 percentage points.

• SNFs are providers that meet Medicare requirements for Part A coverage.

• The 60-day public comment period for the FY 2016 SNF PPS NPRM ends on June 19, 2016.

• Note: Details presented here are proposals and are subject to change in the Final Rule. CMS welcomes public comments.

Introduction: SNF Quality Reporting ProgramFY 2016 SNF PPS NPRM (CMS-1622-P)

Introduction: SNF Quality Reporting ProgramFY 2016 SNF PPS NPRM (CMS-1622-P)

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Page 3: Open Door Forum: SNF Quality Reporting Program Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum FY 2016 SNF PPS NPRM Tara McMullen,

Please refer to the FY 2016 Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities (SNFs) for FY 2016, SNF Value-Based Purchasing Program, SNF Quality Reporting Program, and Staffing Data Collection; Proposed Rule for complete informationavailable at: https://www.federalregister.gov/articles/2015/04/20/2015-08944/medicare-program-prospective-payment-system-and-consolidated-billing-for-skilled-nursing-facilities

FY 2016 SNF PPS NPRM (CMS-1622-P) on Display As of April 20, 2015

FY 2016 SNF PPS NPRM (CMS-1622-P) on Display As of April 20, 2015

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Page 4: Open Door Forum: SNF Quality Reporting Program Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum FY 2016 SNF PPS NPRM Tara McMullen,

• Three proposed post-acute care (PAC) cross-setting measures addressing the following domains:– Skin integrity and changes in skin integrity– Incidence of major falls– Functional status, cognitive function, and changes in function and

cognitive function• Proposed data submission compliance deadlines and thresholds:

– Failure to submit required quality reporting data to CMS will result in a 2% reduction to the FY 2018 market basket percentage

• Proposed SNF QRP Submission Exception and Extension Requirements:– Written request required within 90 days of the date extraordinary

circumstances occurred

SNF Quality Reporting ProgramFY 2016 SNF PPS NPRM (CMS-1622-P)

Policy Proposals

SNF Quality Reporting ProgramFY 2016 SNF PPS NPRM (CMS-1622-P)

Policy Proposals

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Page 5: Open Door Forum: SNF Quality Reporting Program Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum FY 2016 SNF PPS NPRM Tara McMullen,

NQF Measure ID Measure Title Data Collection

TimeframeData Submission

DeadlineNQF #0674 Application of Percent of Residents

Experiencing One or More Falls with Major Injury (Long Stay)

10/01/16-12/31/16

May 15, 2017

NQF #0678 Percent of Patients or Residents with Pressure Ulcers that are New or Worsened

10/01/16-12/31/16

May 15, 2017

NQF #2631* Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function

10/01/16-12/31/16

May 15, 2017

*Status: Under NQF Review

FY 2016 SNF QRP NPRM (CMS-1622-P) Quality Measures

FY 2016 SNF QRP NPRM (CMS-1622-P) Quality Measures

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Page 6: Open Door Forum: SNF Quality Reporting Program Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum FY 2016 SNF PPS NPRM Tara McMullen,

• NQF #2510 Skilled Nursing Facility 30-Day All-Cause Readmission Measure

• Application of the Payment Standardized Medicare Spending Per Beneficiary (MSPB)

• Percentage residents/patients at discharge assessment, who are discharged to a higher level of care or to the community.

Possible Quality Measures for Future YearsPossible Quality Measures for Future Years

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Page 7: Open Door Forum: SNF Quality Reporting Program Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum FY 2016 SNF PPS NPRM Tara McMullen,

• Additional information on the proposed SNF quality measures is available at the following website:http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/SNF-Quality-Reporting-Program-Measures-and-Technical-Information.html

Measure Information Measure Information

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Page 8: Open Door Forum: SNF Quality Reporting Program Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum FY 2016 SNF PPS NPRM Tara McMullen,

Requires SNFs, HHAs, IRFs, and LTCHs to report standardized assessment data on: Specified Assessment Instrument Domains: functional status; cognitive function

and mental status; special services, treatments, and interventions; medical conditions and co-morbidities; impairments; and other categories

Quality Measure Domains: functional status; cognitive function and changes in function and cognitive function; skin integrity and changes in skin integrity; medication reconciliation; incidence of major falls; transfer of health information when the individual transitions from the hospital/critical access hospital to post-acute care (PAC) provider or home, or from PAC provider to another settings

Requires the submission of Data On: Resource Use, and Other Measures: Total estimated Medicare spending per

beneficiary discharged to the community, all condition risk-adjusted potentially presentable hospital readmission rates

Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014

Page 9: Open Door Forum: SNF Quality Reporting Program Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum FY 2016 SNF PPS NPRM Tara McMullen,

The Implementation of Measures Will Evolve Over Time

To meet the October 2016 implementation date for the measure domains specified under the Act for that time frame the following considerations were given:

• Addresses a current area for improvement tied to a stated domain• Consideration of measures previously support by the Measures Application

Partnership (MAP)• Endorsed, implemented/finalized for use in the post-acute care quality reporting

programs (QRPs), e.g., NQF #0678 Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened; NQF # 0674 Percent of Residents Experiencing One or More Falls with Major Injury

• Minimize added burden to the providers • Where possible, avoid any impact on current assessment items already collected • Avoid duplication of existing assessment concepts

Pathway Toward Transformation:Pathway Toward Transformation:

Page 10: Open Door Forum: SNF Quality Reporting Program Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum FY 2016 SNF PPS NPRM Tara McMullen,

• Please submit public comments by 5pm on June 19, 2015 electronically at http://www.regulations.gov OR

• You may mail comments to the following address ONLY: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: PCMS–1622–P, P.O. Box 8016, Baltimore, MD 21244–8016

• More information on the IMPACT Act is available at: http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Post-Acute-Care-Quality-Initiatives/IMPACT-Act-of-2014-and-Cross-Setting-Measures.html

Important Dates & ResourcesImportant Dates & Resources

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Page 11: Open Door Forum: SNF Quality Reporting Program Skilled Nursing Facilities (SNF)/Long Term Care (LTC) Open Door Forum FY 2016 SNF PPS NPRM Tara McMullen,

Questions? Questions?

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