CMS announced a three-year quality improvement initiative in a press release on November 20, 2018. The Civil Money Penalty Reinvestment Program (CMPRP) aims to improve residents’ quality of life by equipping nursing home staff, administrators, and stakeholders with technical tools and assistance to enhance resident care. The CMPRP is funded by federal civil money penalties, which are fines nursing homes must pay CMS by law when they are noncompliant with certain regulations and there are serious concerns about the safety and quality of care they provide.
Skilled Nursing Facility (SNF) Provider Preview Reports have been updated and are now available. Providers have until June 30, 2018 to review their performance data prior to public display on the Nursing Home Compare site. Corrections to the underlying data will not be permitted during this time. However, providers can request a CMS review during the preview period if they believe their data scores displayed are inaccurate.
The Billers’ Association is seeking long-term care managers, revenue cycle enthusiasts, and billing professionals to join our growing ad-hoc list of experts interested in contributing to articles in our monthly publication, Billing Alert for Long-Term Care. This digital newsletter provides expansive regulatory coverage, including MDS changes, reimbursement issues, and expert advice and analysis to help improve job performance in all aspects of the revenue cycle management system.
The key function of any EHR is to collect data, followed closely by a reporting function. These systems are natural links to a QAPI program. Because the backbone of a QAPI program is data, most modern EHR systems available to LTC providers will support various QAPI style reports, such as infection data for infection control.
To help prepare for survey readiness, it is crucial that you regularly audit your facility practices. Many audits can be scheduled routinely, but in all cases, these audits should be performed no later than when the survey window begins. These self-audits help create the survey readiness mode for staff, as auditing creates potential opportunities for improvement through the Quality Assurance and Process Improvement (QAPI) program (determining root causes with Plan of Correction implementation). In fact, the primary source of identification of audits required often comes out of the QA/QAPI program.
Since its initial inception as part of Section 6106 of the Affordable Care Act, the payroll-based journal (PBJ) requirement, which took effect July 1, 2017, has caused long-term care providers several growing pains as the CMS reporting mandate competes with facilities’ many other priorities. Prior to its implementation, in October 2015 CMS launched a voluntary phase of the PBJ reporting system, allowing providers to test their submission process. Few providers participated in the trial run, however, possibly because they were uncertain where their information would end up—or because they were hoping the government program would be postponed.
There is an old joke/riddle that goes like this: “Where does an 800 lb. gorilla sit? Answer: Anywhere it wants to”. For SNFs and REITs today, that gorilla is Medicaid. Sure, there are numerous industry headwinds that SNFs face in terms of financial performance
The challenge for skilled nursing facility (SNF) providers today is less about census and more about payer mix.
Providers must develop a strong and replicable quality mix—one that, with the application of good marketing strategy and business development techniques, sources desired referrals consistently and dependably. In this manner, the SNF achieves occupancy and revenue targets consistent with its business or strategic plan. From a business development perspective, the strategy and thus the results are organic—naturally occurring as a result of operational standards and care outcomes.
CMS published the Final Rule to Reform Requirements for Long Term Care Facilities on October 4, 2016, with an effective date of November 28, 2016. Survey protocols and interpretive guidelines were published on March 8, 2017, in Appendix PP of the State Operations Manual. One of the new requirements for nursing facilities is to implement a compliance and ethics program in the last phase of the timetable for changes. Due to the time and resources needed to achieve compliance with the new requirements, surveyors will not begin surveying for compliance with this change until November 28, 2019.
Medicare health plans, which include Medicare Advantage (MA) plans – such as Health Maintenance Organizations, Preferred Provider Organizations, Medical Savings Account plans and Private Fee-For-Service plans – Cost Plans and Health Care Prepayment Plans, must meet the requirements for grievance and appeals processing under Subpart M of the Medicare Advantage regulations. For a detailed discussion of the Medicare managed care grievance and appeals processes, click here.