AHCA has prepared an update on the Skilled Nursing Facility (SNF) Quality Reporting Program (QRP), which includes background information on the program, 2018 and 2019 SNF QRP impacts on payment updates, and practical steps you can take to ensure your MDS includes all the right data.

Background
The SNF QRP was established by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014. It requires that providers complete certain uniform data elements in the Minimum Data Set (MDS) that can also be found within the assessment instrument used by long-term care hospital (LTCH), inpatient rehabilitation facility (IRF), and home health agency (HHA) providers. These data elements will be used in the calculation of three quality measures currently used in SNF QRP:

1. Application of Percent of Residents Experiencing One or More Falls with Major Injury
2. Percent of Patients or Residents with Pressure Ulcers that are New or Worsened
3. Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Function Assessment and a Care Plan that Addresses Function

CMS requires SNFs complete all the MDS items necessary to calculate the three measures for at least 80 percent of assessments used for the quality measure. Providers that fail to meet this 80 percent data completeness threshold will have their Medicare annual payment update (APU) reduced by two percentage points each fiscal year (FY) beginning with FY 2018. 

First SNF QRP Impact – FY 2018
The first SNF QRP reporting deadline passed on June 1, 2017, for the data collection period of quarter 4, 2016. AHCA was pleased to hear from CMS that the overwhelming majority of SNFs met the SNF QRP reporting requirements threshold, and were not adversely affected by the APU update reduction.  

Second SNF QRP Impact – FY 2019
The second reporting period for SNF QRP which will impact FY 2019 APU has already begun. It is critical for all SNFs to have processes in place to audit and correct in a timely manner before each upcoming quarterly data submission deadline closes. This second SNF QRP reporting requirement period will include all four quarters of calendar year 2017 with the following reporting deadlines:

 Opportunities for Action

• Know the MDS items used in the assessment-based SNF QRP measures and audit for accuracy.
  There are over 50 MDS items involved in the calculation of these three assessment-based SNF QRP measures. Each item with coding values that may count against APU are listed and sorted by each measure on this document here.

• Pay attention to Section GG coding in MDS.
  -Section GG was newly added to the MDS in October 1, 2016.  Items in this section are used to calculate the SNF QRP function measure. An analysis of the MDS in quarter 4, 2016, found that most coding values that count against APU are related to dash coding in section GG.

• Explore process improvements to reduce dash (-) coding on MDS items where appropriate.
  -Dash (-) coding, which indicates no information on MDS items used to calculate the SNF QRP assessment-based measures, may count against APU due to the SNF not meeting the reporting requirement threshold. There may be opportunities to change processes in your center in order to collect information on MDS items that are currently being dashed, thus allowing a response that will not count against the SNF QRP reporting requirements.

• Verify MDS assessments are accurately completed and submitted as required, particularly 5-day prospective payment system (PPS) and SNF Part A PPS Discharge or Omnibus Budget Reconciliation Act (OBRA) discharge assessments.
  -Use the applicable reports available in CASPER to validate MDS completion and submission accepted. SNF QRP measures are stay-based and calculated using the 5-day PPS for the admission and either the SNF Part A PPS Discharge or the OBRA Discharge, depending on which the SNF submits to CMS.
  

AHCA Advocacy & Reports from CMS to SNFs

AHCA has been meeting with CMS routinely to advocate for meaningful reporting to SNFs regarding QRP requirements. CMS made SNF QRP Review & Correct Reports, which report a SNF’s performance rate on each SNF QRP measure, available to SNFs beginning this summer. Per CMS, these reports are intended to provide advance review of SNF QRP performance rates before public reporting in the future. Please note these reports do not reflect SNFs performance related to the SNF QRP reporting requirement associated with the APU potential reduction for applicable fiscal year. 

AHCA has advocated for patient level data to aid in SNFs’ process improvement efforts to meet SNF QRP reporting requirements as well as to better understand the SNF QRP measures in application to practice. We are pleased to share that CMS plans to provide patient-level reporting on SNF QRP assessment-based measures in late fall 2017. We will share more information as soon as it becomes available.

CMS has begun providing email notices to SNFs in advance of each quarterly data submission deadline to alert SNFs of missing data for one or more of the SNF QRP measures. This notice has already been sent for the prior 2017 data collection period.

AHCA will continue to advocate for CMS to provide additional details in these communications to aid SNFs in identifying areas for performance improvement.

CMS can be contacted about SNF QRP questions at SNFQualityQuestions@cms.hhs.gov.