Changes to CMS Five-Star: What Investors and Operators Need to Know
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1 Changes to CMS Five-Star: What Investors and Operators Need to Know Thursday, March 8, :00 PM 5:15 PM Dallas Ballroom F #NICForum18
2 Please Complete the Session Evaluation Mobile App Home Page Session Evaluations #NICForum18
3 Complete the Credit and Evaluation Forms Forms submitted without a License # cannot be approved #NICForum18
4 Session Presentations Mobile App Home Page NIC Resources #NICForum18
5 Speakers Steven Littlehale, MS, GCNS-BC EVP & Chief Clinical Officer PointRight Inc. Eric Gillis, MBA Director of Asset Management CareTrust REIT 5
6 Why do we bother with clinical outcomes data? 6
7 From Volume to Value and Its Impact on SNFs Viability Success is: Determined on clinical outcomes playing field Requires metrics be monitored and properly managed Rehospitalization Swish! 7
8 Key Metrics from PointRight Available Soon to NIC MAP Subscribers and Skilled Nursing Data Contributors State/Metro Level Report Property Level Report 8
9 Five Star A Quick Overview 9
10
11 The primary goal in launching this rating system is to provide residents and their families with an easy way to understand assessment of nursing home quality, making meaningful distinctions between high and low performing nursing homes. CMS s Technical Users Guide July 2009
12 I need a nursing home for my wife. I cannot afford a Five-Star or even a Four-Star home, can you recommend a Three-Star? Consumer in Florida March 2010
13 CMS Five-Star Program The rating system features an overall Five-Star rating based on facility performance for three types of performance measures: Health Inspection Staffing Quality Measures The rating system has been available to the public on CMS website Nursing Home Compare since December 18,
14 1.3 million page views per month
15 Five-Star does nothing to match the right person to the right SNF All SNFs are not the same De facto specialty care centers Acute Medical/Rehab Alzheimer's/Cognitive Impairment Mental Health End of Life/Frail Elders All consumers coming into a SNF are not the same Some are patients and will be going home Some are residents and will not All have unique needs 15
16 Add 1 Star to Overall Add 1 Star to Overall 4 or 5 and >HI 5 1 Initial Health Inspection Rating (HI) 2 Staffing Rating 3 QM Rating 4 Overall Five Star Rating 1 1 Minus 1 Star to Overall Minus 1 Star to Overall
17 Who s Using It and Why? 17
18
19 Five-Star Uses (and Abuses) are Far Ranging Intended Uses Consumer placement Consumer monitoring of care Unintended Uses APM (ACOs, Bundles) HUD Commercial payers Plaintiff Attorney REITs 19
20 APM: What is a Three-Day Requirement & Waiver? Requirement: Qualifying inpatient hospital stay of 3 consecutive days (midnights) or more (plus additional criteria) Waiver: For eligible programs, CMS will waive the requirement for a 3-day inpatient hospital stay prior to a Medicare-covered, post-hospital extended care service for eligible beneficiaries 20
21 A Waiver is a good thing For the ACO/Bundle it means the possibility of transitioning patient to lower cost center (the SNF) For the SNF, it means a potentially better referral stream of higher acuity residents The spill over effect a hospital discharge planner knows what she knows other FFS patients may turn up in same hospital to SNF stream So how do you get one? 21
22 Who Gets a Three Day Waiver? SNF must have a 3 or better Overall Star Rating ACO Track +1, Track 3 and Next Gen Bundles: For Model 2/Model 3 participants but there is always a catch! 22
23 Five-Star Ratings & Rehospitalization Rates Overall Rating Jun-17 Median Observed Rehospitalization Rate Median Adjusted Rehospitalization Rate PointRight Inc. 2018
24 Five-Star Ratings & Rehospitalization Rates PointRight Inc. 2018
25 Litigation 25
26 Are PL Claims >250K Correlated to Five-Star? Five-Star Domain overall health inspection quality staffing Yes! Yes! No! Yes! 26
27 Evaluating REIT: The Role of Five-Star Monitoring 27
28 Change is in the Air 28
29 Health Inspection and Staffing Domains Remember that HI has most significant impact on Five-Star Staffing domain has the second impact score Anytime these domains are touched, facility-level five-star changes occur CMS has not released technical manuals that reflect these impending changes 29
30 Health Inspection Deficiency data* from complaint or standard surveys post Nov 28 th are not included until further notice (effective: Jan 2018) Traditionally three survey cycles were used in calculation, this will reduce to two (effective: March 1) Most recent survey cycle/year will be weighted 60%, second most recent, weighted 40%. Technical specification was released March 2nd * This deficiency data is posted on NHC 30
31 The Winners and the Losers An Approximation Health Inspection Domain About 20% of SNFs will see a change in their health inspection domain 1329 will see a decrease 1726 will see an increase Overall Five-Star 15% of SNFs will see a change in Overall Stars 1017 will see a decrease in Star Rating 1266 will see an increase in Star Rating 303 will lose their 3 Star Rating 348 will obtain a 3 Star Rating If in Jan 18 three cycles were to reduce to two 31
32 Electronic Submission of Staffing Data The Affordable Care Act requires facilities to electronically submit direct care staffing information based on payroll and other auditable data. Combined with census information will be used to report on staffing levels Includes agency and contract staff CMS deployed system to allow for submission of staffing: the Payroll- Based Journal (PBJ). Staffing is submitted quarterly It will also be auditable to ensure accuracy and compliance Noncompliance will be subject to CMS enforcement actions 32
33 Staffing Data
34 The Potential Five-Star Impact Staffing Type N Mean Median RN HPRD from CMS 671 (Sep-17) 14, RN HPRD from Q PBJ file when LPNs with admin duties are still counted under RN 14, RN HPRD from Q PBJ file 14, * N only includes providers that have a non-missing value for both CMS-671 and PBJ staffing. PointRight Inc. 2018
35 PBJ vs CMS Staff Type N Median CMS Median PBJ Median Difference (PBJ 671) Median Percent Difference RN HPRD 14, % LPN HPRD 14, % Aide HPRD 14, % Total HPRD 14, % * N only includes providers that have a non-missing value for both CMS-671 and PBJ staffing. PointRight Inc. 2018
36 Removing LPN w/admin Duties from RN Bucket RN Staffing Rating Sep-17 % of SNFs - Today % of SNFs - PBJ data (removing LPN with admin duties) PointRight Inc
37 Then Recalculate Staffing Domain Staffing Rating Sep-17 % of SNFs - Today % of SNFs - PBJ data (removing LPN with admin duties) PointRight Inc
38 Then Recalculate Overall Five-Star Overall Rating Sep-17 % of SNFs - Today % of SNFs - PBJ data (removing LPN with admin duties) PointRight Inc
39 PBJ Staffing Data: Key Differences to Keep in Mind Salaried workers that pick up additional shifts will not have those hours counted, unless paid a bonus for those hours If an employee performs multiple job functions, code them to primary function Focus is on auditable data that can be verified Hours paid for services performed onsite, not including lunch, sick leave, vacation Corporate staff can be counted in some instances but must be auditable Contract/agency staff must be reported Census is calculated by MDS essential that discharge assessments be completed
40 Staffing and Rehospitalization, and other key findings MHPs pain, pressure ulcers ER use immunizations pressure ulcers pain Pharmacists immunizations pressure ulcers pain RN Staffing Higher RN staffing is by far the most powerful thing in better PAC outcomes NP NP FTE 0.5 ER use rehosp ROC pressure ulcers antipsychotics Medical Director Medical Director > 0.2 FTE ER use rehosp ROC pressure ulcers antipsychotics 40
41 How do these changes impact the REIT? Evaluating Monitoring 41
42 Conclusion What is Certain Key clinical outcomes are essential KPIs to track Five-Star has an impact on a SNFs success Five-Star is changing What is Less Certain Technical details around Five-Star changes Timing of Five-Star changes Future impact on SNFs of volume to value 42
43 Audience Questions Please Take a Few Minutes to Complete Today s Session Evaluation #NICForum18
44 Thank You! Steven Littlehale EVP & Chief Clinical Officer, PointRight Eric Gillis Director of Asset Management, CareTrust REIT #NICForum18 44
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