Five Star Survey Calculation Question Answered - According to Center for Medicare and Medicaid Services (CMS) the November 24th Survey and Certification Memo (S&C 18-04-NH), survey results occurring between November 28, 2017, through November 27, 2018, will not be incorporated into the Inspection Star Rating on the Nursing Home Compare website. Star ratings will be based on the two most recent cycles of findings for standard health inspection surveys and the two most recent years of complaint inspections. This "freeze" will be going into effect early in 2018 and is slated to last approximately one year. This does NOT mean that your star rating will remain the same. Changes could still occur. There will be no freeze on the Quality Measures (QMs) or staffing domains.
Calculations will be made by removing the third (oldest) cycle of health inspection survey/complaint investigation data. The most recent cycle of data will be assigned 60% of the weight and the prior cycle will receive 40% of the weight in the new calculation. CMS states they will be updating the "Five Star Quality Rating System Technical User's Guide" to reflect these changes.
The NEW Survey Process has started.
The "blended" Long Term Care Survey Process (LTCSP) took effect on November 28th, 2017, and while there has not been time to collect outcome data, here is what some individuals who have been surveyed under the revised process shared:
- Surveyors are taking time to learn the ropes, making the process a little more time consuming.
- There have been MANY changes in the resident selections based on observations made by surveyors during the initial facility walk-through.
- Not everything is cut and dry. This process allows for more subjectivity. Sharing pertinent information with a surveyor about an issue they are considering for citation is key. The best approach is to provide a clear picture or timeline of the care and services that were provided to address any noted concerns or areas of focus.
What does this mean for facilities who are due a survey? Be prepared, remember that initial facility round is very important in establishing the sample, be patient, and be willing to professionally challenge issues that arise if you have a
valid "leg to stand on" or argument.
The Medicare Payment Advisory Committee (MedPAC) recently shared that 2016 SNF Medicare dollars reached $29 billion dollars, making up 11% of the total days per facility average and accounting for 20% of the revenue. Using the data in their trending analysis, MedPAC is recommending the following:
- Elimination of the market basket update for SNFs for fiscal years (FY) 2019 and 2020.
- Implementation of a redesigned Prospective Payment System (PPS) in FY 2019 known as the Resident Classification System Version 1 (RCS-1).
- Monitoring and reporting on the outcome of the revised PPS to allow for additional measures to more closely align payments with costs in FY 2021.
Coming Down the Pike
CMS has shared that Medicare Recovery Audit Contractors (RACs) will have new Additional Documentation Request (ADR) limits in the near future. The new ADR policy that is slated to go into effect soon has a loophole that allows very low volume Medicare providers (fewer than 1599 particular claims per year) exemption from review. This would include many of the small hospital based units.
The new policy also reduces the annual ADR limit to 0.5% of any provider's total number of paid Medicare claims.
Follow-up to November
On December 14, 2017, the Medicare Learning Network (MLN) held the National Partnership to Improve Dementia Care in Nursing Homes & Quality Assurance and Performance Improvement (QAPI) webinar. The handouts are currently available on the
CMS National Provider Calls and Events website
. A recording of the call will be available on the same website within the next two weeks.
ACT Senior Living Consulting Services
The ACT Senior Living Consulting team can help you before, during, or after a survey. We can provide assistance to:
- Develop a survey plan
- Educate staff
- Identify and fix broken systems
- Monitor and abate situations that may arise during the surveyors' visit
- Write and achieve a successful Plan of Correction (POC)
- Develop auditing systems to ensure that expectations are being monitored
- Research, write, and submit an effective Informal Dispute Resolution (IDR) request
Contact us by email to determine how we can meet your needs, email us at
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