What’s happening: CMS released QSO-23-21-NH announcing updates coming Nursing Home Care Compare Staffing and Quality Measures in April 2024.

• The updates accommodate previously announced MDS changes effective October 1, 2023. This includes changes to the staffing level case-mix adjustment methodology from RUG-IV to PDPM.
• CMS announced it will be removing the CMS-672 form (Resident Census and Conditions of Residents) as well as other changes related to turnover scoring, and ratings freeze periods.  

Implications for Virginia: VHCA-VCAL met with DMAS to discuss potential impacts of these changes on the Medicaid Value-Based Purchasing (VBP) Program related to the metrics for pressure ulcers and total staffing.

• We believe DMAS will likely include some “flexibility” language in the soon-to-be-released 2025 Methodology document as we continue to discuss these impacts. This will not impact the VBP program this year (payments in Spring/Summer 2024), but will affect these metrics’ results during the October 1, 2023 through September 30, 2024 performance measurement period (payments in Spring/Summer 2025); the pressure ulcer metric also affecting the fourth year of VBP for one quarter (as currently indicated by CMS).

Changing turnover scoring when PBJ data is missing: Beginning in April 2024, CMS will revise the staffing rating methodology so providers that fail to submit staffing data or submit erroneous data receive the lowest score possible on the corresponding staff turnover measures. 

• The PBJ-based turnover measures require six consecutive quarters of data. Currently, nursing homes that fail to submit data to calculate staff turnover have their staff turnover measures excluded from the staffing rating calculation.
• No changes were made to the impact of missing PBJ data on the calculation of hours per resident day measures and the automatic downgrade to one-star if the most recent quarter of PBJ data is missing. 

Freezing staffing ratings from April – June 2024 to transition case-mix adjustment to PDPM: Beginning in April 2024, CMS will freeze (i.e., hold constant) the staffing measures and ratings for three months.

• During this time, CMS will transition from RUG-IV to PDPM case-mix adjustment because MDS Section G will be eliminated on October 1, 2023 – case mix impacts the adjusted total staffing ratio used in the Virginia Medicaid Nursing Facility VBP Program.
• The specific methodology using PDPM will be released in July 2024, and it will include revising the staffing rating thresholds to maintain the same distribution of staffing points and ratings. 

Freezing four of the 15 quality measures in Five-Star starting April 2024: CMS will freeze the following four measures starting in April 2024 because of the MDS transition from Section G to GG on October 1, 2023:

• percentage of residents who made improvements in function (short stay);
• percent of residents whose need for help with activities of daily living has increased (long-stay);
• percentage of residents whose ability to move independently worsened (long-stay); and
• percentage of high-risk residents with pressure ulcers (long stay) – a Virginia Medicaid Nursing Facility VBP Program metric. 

CMS will replace the short-stay functionality measure with the new functionality measures from the Quality Reporting Program (QRP) in October 2024.

• The other three measures will remain frozen until January 2025. During the freeze, the measures will continue to count towards Five-Star quality ratings at the rate when the freeze takes effect.  

Updating CMS forms 671 and 672: CMS cited changes to the MDS as the reason for the removal of the CMS-672 form related to information needed to complete the form will no longer be available, due to the removal of Section G on the MDS. The changes will occur over several weeks as outlined in QSO 23-21-NH. 

• Effective September 29, 2023:
• Facilities will no longer be required to complete fields F79-F145 on the CMS-672. 
• Surveyors will no longer be required to complete some portions of the form effective this date. 
• Effective October 22, 2023: 
• CMS-672 form will be removed. 
• The census, medication error rate, and ombudsman information will be moved to CMS-671.