Wednesday, December 30, 2015

From Texas RAI Manager: Reversal of previous CMS position on "present on admission"

CMS Clarifies Coding “Present on Admission” for Pressure Ulcers in MDS Item M0300

Question:

A resident was admitted with a pressure ulcer that was “present on admission”. The resident both discharged return anticipated to the hospital and then returned to the facility within 30 days with the same pressure ulcer at the same stage. Can the pressure ulcer be coded in item M0300 as present upon admission/entry or reentry?

Clarification:

The MDS 3.0 RAI User's Manual, Chapter 3, page M-7 contains the following instructions for determining if a pressure ulcer was “present on admission”:
“For each pressure ulcer, determine if the pressure ulcer was present at the time of admission/entry or reentry and not acquired while the resident was in the care of the nursing home. Consider current and historical levels of tissue involvement…
Step 4: If a resident who has a pressure ulcer is hospitalized and returns with that pressure ulcer at the same numerical stage, the pressure ulcer should not be coded as "present on admission" because it was present at the facility prior to the hospitalization.”
  • If the resident was admitted to the facility with a pressure ulcer, was subsequently transferred to the hospital with the same pressure ulcer at the same stage as it was at the time of admission, and then returned to the facility with that same pressure ulcer at the same stage, it should be coded as “present on admission” in item M0300. It is coded as “present on admission” because it was not acquired while the resident was in the care of nursing home staff.
  • If the pressure ulcer was not “present on admission” when it was identified by nursing home staff or if a pressure ulcer that was “present on admission” increased in stage while receiving nursing home care, it would NOT be coded as “present on admission” when the resident returned from the hospital with the ulcer at the same stage as it was when they left. This is because the ulcer was either acquired or worsened to a higher stage while under the care of nursing home staff.
As required on page 5-10 of the MDS 3.0 RAI User's Manual, nursing home staff should correct all MDS that were not appropriately coded in this fiscal year (since 10/1/15) within 14 days of reading this clarification and noting the error. Modifications to correct the errors must be made, even though there will be no impact on the Resource Utilization Group (RUG) used for payment and no impact on nursing home quality measures.
Posted: 12/30/2015

Sunday, December 27, 2015

Another Focus Survey Pilot


It appears that we will see a rash of these as they test tools to update the survey process as the new Conditions of Participation make their way into the SOM over the coming years.  Note this one does not involve citations.  It will be surveyors in the building, and they can always call in complaints on any topic.  We must respond in full survey mode.

Infection Control Pilot Project
Memo # 16-05-ALL
Posting Date 2015-12-23
Fiscal Year 2016

Memorandum Summary 

• Project Overview: The Centers for Medicare & Medicaid Services (CMS) has begun a three year pilot project to improve assessment of infection control and prevention regulations in nursing homes, hospitals, and during transitions of care. 
• Survey details: All surveys during the pilot will be educational surveys (no citations will be issued) and will be conducted by a national contractor. New surveyor tools and processes will be developed and tested, focusing on existing regulations as well as recommended practices (such as those for antibiotic stewardship and transitions of care). Ten pilot surveys to be conducted in Fiscal Year (FY) 2016 will occur in nursing homes. Surveys in FY17 and FY18 will be conducted in nursing homes and hospitals. 
• Project Outcomes: New surveyor infection control tools and survey processes that can be used to optimize assessment of new infection control regulations. 

Monday, December 21, 2015

DMAS released draft MLTSS Datebook: Virginia Medicaid Providers - Chance to provide input

Attention MLTSS Interested Stakeholders:

In keeping with our commitment for transparency and garnering on-going stakeholder input, DMAS in collaboration with PricewaterhouseCoopers LLP (PwC), is pleased to provide stakeholders with a draft MLTSS Databook.  The draft Databook provides detailed information about the service utilization for the MLTSS population. DMAS encourages stakeholders including interested health plans to raise questions that can help to improve the understanding and usefulness of the databook.  We expect that some questions may lead to the need for further analysis, or even revisions to the databook, before DMAS releases the RFP.  The draft MLTSS Databook and other background information on MLTSS is available on the DMAS website at:  http://www.dmas.virginia.gov/Content_pgs/mltss-home.aspx.  We ask that you send your questions/ comments related to the Databook by January 31, 2016.  Please direct all questions and comments via email to: VAMLTSS@dmas.virginia.gov.  

Thank you.

Tammy Driscoll
Senior Programs Advisor to the Deputy of Complex Care and Services
Virginia Department of Medical Assistance Services (DMAS)
600 East Broad Street
Richmond, VA 23219
804-225-2552

Friday, December 18, 2015

Virginia Survey Stakeholder Meeting (NFAC): Virginia will be doing 6 MDS/Staffing Focused Surveys in Fy2016 and they want to get them done early

Announced in the Nursing Facility Advisory Committee meeting yesterday by Survey Director:
They are going to do 6 (same number as 2015).  They are selected and they want to get them done early.

Monday, November 30, 2015

GAO Report on Nursing Home Quality Published Oct 30, 2016

What GAO Found

In recent years, trends in four key sets of data that give insight into nursing home quality show mixed results, and data issues complicate the ability to assess quality trends. Nationally, one of the four data sets—consumer complaints—suggests that consumers' concerns over quality have increased, while the other three data sets—deficiencies, staffing levels, and clinical quality measures—indicate potential improvement in nursing home quality. For example, the average number of consumer complaints reported per home increased by 21 percent from 2005-2014, indicating a potential decrease in quality. Conversely, the number of serious deficiencies identified per home with an on-site survey, referred to as a standard survey, decreased by 41 percent over the same period, indicating potential improvement. The Centers for Medicare & Medicaid Services' (CMS) ability to use available data to assess nursing home quality is complicated by various issues with these data, which make it difficult to determine whether observed trends reflect actual changes in quality, data issues, or both. For example, clinical quality measures use data that are self-reported by nursing homes, and while CMS has begun auditing the self-reported data, it does not have clear plans to continue. Federal internal control standards require agencies to monitor performance data to assess the quality of performance over time.
In recent years, CMS has made numerous modifications to its nursing home oversight activities, but has not monitored the potential effect of these modifications on nursing home quality oversight. Some of the modifications have expanded or added new oversight activities, while others have reduced existing oversight activities. According to CMS, some of the reductions to oversight activities are in response to an increase in oversight responsibilities and limited number of staff and financial resources. However, CMS has not monitored how the modifications might affect CMS's ability to assess nursing home quality. For example, CMS reduced the number of nursing homes participating in the Special Focus Facility program—which provides additional oversight of homes with a history of poor performance—from 152 in 2013 to 62 in 2014. State survey agency officials who conduct surveys for CMS also made modifications which could have either a positive or negative effect on oversight, but CMS does not have an effective mechanism for monitoring. Federal internal control standards require ongoing monitoring as a part of normal program operations; without this monitoring, CMS cannot ensure that any modifications in oversight do not adversely affect its ability to assess nursing home quality.
Highlights - www.gao.gov
Podcast - www.gao.gov

Wednesday, November 25, 2015

New SNF Booklet Published by CMS September 2015

CMS has published a new SNF booklet here.  Note that it mentions SNF QRP,  because we will  lose 2% of our FY 2018 SNF payment if we do not report at least 80% of the three QMs with 100% of the data fields on the MDS. The collection period for these three QMs to establish penalties for FY18 is Oct, Nov and Dec of 2016.

Monday, November 16, 2015

Comprehensive Care for Joint Replacement (CJR) Model

FACT SHEET 


FOR IMMEDIATE RELEASE
November 16, 2015                                                                                                                          

Contact: CMS Media Relations
(202) 690-6145 | CMS Media Inquiries

Comprehensive Care for Joint Replacement (CJR) Model
Hip and knee replacements are the most common inpatient surgery for Medicare beneficiaries and can require lengthy recovery and rehabilitation periods. In 2014, there were more than 400,000 procedures, costing more than $7 billion for the hospitalizations alone.
Yet, the quality and cost of care for these hip and knee replacement surgeries still varies greatly. For instance, the rate of complications like infections or implant failures after surgery can be more than three times higher for procedures performed at some hospitals than others. And the average total Medicare expenditure for surgery, hospitalization, and recovery ranges from $16,500 to $33,000 across geographic areas.
This variation is due partly to the way Medicare beneficiaries receive care. Incentives to coordinate the whole episode of care – from surgery to recovery – are not strong enough, and a patient’s health may suffer as a result. When approaching care without seeing the big picture, there is a risk of missing crucial information or not coordinating across different care settings. This approach leads to more complications after surgery, higher readmission rates, protracted rehabilitative care, and variable costs. These are not the health outcomes patients want.
The Comprehensive Care for Joint Replacement (CJR) model addresses low quality and high costs that come from fragmentation by promoting coordinated, patient-centered care. This model aims to improve the care experience for the many and growing numbers of Medicare beneficiaries who receive joint replacements, making the patient’s successful surgery and recovery a top priority for the health care system.
How the CJR model helps—and protects—beneficiaries:
  • Patients can benefit from their hospitals and other health care providers (e.g., physicians, home health agencies, and nursing facilities) working together more closely to coordinate their care. Coordination of care leads to better outcomes, a better experience, and fewer complications, such as preventable readmissions, infections, or prolonged rehabilitation and recovery.

  • Beneficiaries will benefit from protections including: additional monitoring of claims data from participant hospitals to ensure that hospitals continue to provide all necessary services; continued protection of patient data under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and other applicable privacy laws; and patient notification by providers and suppliers. Further, all existing safeguards to protect beneficiaries and patients will remain in place. If a beneficiary believes that his or her care has been adversely affected, he or she can call 1-800-MEDICARE or contact his or her state’s Quality Improvement Organization (QIO) by going to http://www.qioprogram.org/contact-zones. If concerns are identified, CMS will initiate audits and corrective action under existing authority.

  • Patients can continue to choose their doctor, hospital, skilled nursing facility, home health agency, and other provider, but now with the CJR model, their providers have incentives to better coordinate their care. From surgery to recovery, patients can receive more comprehensive, coordinated care from their providers focusing on the most appropriate options for their recovery and rehabilitative care.

How the CJR Model works:
  • CMS has learned from other models and projects already underway and has incorporated successful design elements from other initiatives into the CJR model design. The CJR model also reflects best practices in the private sector.

  • Under this model, the hospital in which the hip or knee replacement and/or other major leg procedure takes place will be accountable for the costs and quality of related care from the time of the surgery through 90 days after hospital discharge—what is called an “episode” of care.

  • Depending on the hospital’s quality and cost performance during the episode, the hospital will either earn a financial reward or, beginning with the second performance year, be required to repay Medicare for a portion of the spending above an established target. This payment structure gives hospitals an incentive to work with physicians, home health agencies, skilled nursing facilities, and other providers to make sure beneficiaries receive the coordinated care they need with the goal of reducing avoidable hospitalizations and complications. Hospitals in the model will be provided access to additional tools – such as spending and utilization data and sharing of best practices -- to improve the effectiveness of care coordination.       The model also gives providers additional flexibilities that are not otherwise available under Medicare so they can better manage the care of patients, including patients who are at home.

  • By “bundling” payments for an episode of care, hospitals, physicians, and other providers have an incentive to work together to deliver more effective and efficient care.

  • This model is being tested in 67 geographic areas throughout the country, and nearly all hospitals in those geographic areas are required to participate.

Reasons for the CJR Model:
  • Lower extremity joint replacements are the most commonly performed Medicare inpatient surgery, and utilization is predicted to continue to grow. These surgeries can require long recoveries that may include extensive rehabilitation or other post-acute care, which provides many opportunities to reward providers that improve patient outcomes.

  • By including all eligible hospitals in 67 geographic areas across the country, this model drives significant movement towards new payment and care delivery models for an important set of conditions and surgeries for Medicare beneficiaries.

  • This model supports HHS efforts to transform the health care system towards one focused on better quality care, smarter spending, and healthier people through care transformation and payment reform.

For more information, visit: https://innovation.cms.gov/initiatives/cjr
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