CMS has announced yesterday two new rules that, according to a CMS press release, will place more focus on SNF residents as a priority over paperwork by reducing unnecessary regulations and protecting their legal interests. The proposed rule would delay Phase 3 requirements, including QAPI and ethics and compliance standards. The final rule upends the ban on SNFs offering arbitration agreements to residents. These changes, fueled by the Trump administration, will modify previous rules set forth between October 2016 and June 2017.
Providing excellent care and delivering successful resident outcomes are goals for which all facilities should strive. In order to achieve these goals, it is important to focus on what can be done to improve collaboration and teamwork. A true collaboration can result in the following:
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