Quality Outcomes and Data Collection Presented By: Joanne Jones Director, Clinical Consulting Services August 30, 2016 Quality Measurement in LTC CMS Nursing Home Compare 5 Star Rating System New measures published April 2016 NYS Nursing Home Quality Initiative (NHQI) Revision to staffing measure 2016 SNF Quality Reporting Program IMPACT ACT Data collection starts October 1, 2016 SNF Value Based Purchasing Program (SNFVBP) Affects Medicare Fee for Service Payment FY 2019 1 1
Quality Measures in Long Term Care Use of Quality Measures Quality Improvement Internal use of data to identify problems or opportunities for improvement Accountability Nursing Home Quality Indicator Survey Process (QIS) Consumer decision making Criteria for waiver of 3 day Hospital stay for bundled payments Value based Payment Systems Transitioning payment based on quantity to quality 2 Quality Measures in Long Term Care Sources for Data Clinical Data Minimum Data Set ( MDS) Transitions in Care Data Medicare Fee for Service Claims Data NYS SPARCs Data Financial Data Medicare Fee for Service Claims Data NYS Cost Report (RHCF) 3 2
CMS Nursing Home Compare 5-Star Rating Quality Measure Overview Short Stay Measures Residents in Facility 100 days or less Long Stay Measures Residents in Facility 101 days or more Volume measures vs. Comparative measures Volume = Prevalence of conditions or care needs Comparative = changes in condition between multiple MDS 4 CMS Nursing Home Compare 5-Star Rating Quality Measure Updates Updated data is posted quarterly January/April/July/October Data reflected of most recent 4 calendar quarters ( changed July 2016) July 2016 = April 2015 thru March 2016 October 2016 = July 2015 thru June 2016 January 2017 = October 2015 thru September 2016 5 3
CMS Nursing Home Compare 5-Star Rating Impact on CMS Overall 5-Star Rating Quality Measures Star rating can either improve or reduce your overall score QM Score of 5-Stars raises overall score by 1 Star QM Score of 1-Star reduces overall score by 1 Star Example Health Inspection star rating = 4 Staffing Star rating = 2 Quality Measure Star rating = 5 Overall Star rating = 5 6 CMS Nursing Home Compare 5-Star Rating Impact on CMS 5-Star Rating 3 Short Stay QM Pain Worsening Pressure Ulcers New Antipsychotic medication 7 4
CMS Nursing Home Compare 5-Star Rating Impact on CMS 5-Star Rating 8 Long Stay QM Falls Pain Prevalence of Pressure Ulcers Urinary tract Infections Catheter use Restraints ADL decline Antipsychotic medication use 8 CMS Nursing Home Compare 5-Star Rating New Quality Measures April 2016 Includes 3 claims-based measures Claims-based measures are short stay only Includes data from Medicare fee-for-service claims only Claims-based measures reflect rolling 12-month period Updated every six (6) months ( April October) April claims-based measures reflect July 2014 thru June 2015 October claim based measures reflect January 2015 thru December 2015 9 5
CMS Nursing Home Compare 5-Star Rating Short stay claims-based measures (3) Percentage re-hospitalized within 30 days of admission to SNF Includes inpatient and observation stays Excludes hospice and planned hospital admissions Percentage successfully discharged to the community Successful discharge defined as no hospital or SNF admission or death within 30 days of discharge from SNF Excludes hospice and those in nursing home prior to hospital admission 10 CMS Nursing Home Compare 5-Star Rating Short stay claims-based measures (3) Percentage who have an outpatient emergency room visit Based on Part B claims Time frame is within 30 days of admission to a SNF 11 6
CMS Nursing Home Compare 5-Star Rating Short stay MDS based measures (1) Percentage who made improvements in function Measures self performance in transfers, locomotion on unit, walk in corridor Measure from 5 day PPS MDS to discharge return not anticipated MDS 12 CMS Nursing Home Compare 5-Star Rating Long Stay Measures (2) Percentage whose ability to move independently worsened Based on decline in self performance for locomotion on unit Triggered by increase of 1 or more in score Prevalence of Antianxiety/Hypnotic Medication No risk adjustment Excludes hospice or life expectancy of less than 6 months Will not affect 5-Star rating 13 7
CMS Nursing Home Compare 5-Star Rating July 2016 Quality Measure Update Phase in of claims based measures impact to QM Star rating 50% for July 2016 transitioning to 100% in January 2017 Preliminary review of the results The new measures have negatively affected the QM Star rating for facilities that scored less than 50% of the new measures assigned points. 14 NYS Nursing Home Quality Initiative Established in the 2010 2011 NYS Executive Budget 2012 compliance only 2013 forward added reporting of Quality Measures Currently $50M in project $50M is currently in the Medicaid rates and will be removed and paid to facilities ranked in the top 3 quintiles To date, FFS Medicaid rates do not reflect any adjustments 15 8
NYS Nursing Home Quality Initiative Overall Per Diem Calculation Net per diem amounts 2013 net impacts range from $(2.62) to $3.19 per day* 2014 net impacts range from $(2.97) to $3.62 per day* * Per NYSDOH Nursing Home Bench Mark Rates. 16 NYS Nursing Home Quality Initiative Components of Calculation Quality Component 70 points Compliance Component 20 points Timely submission of cost reports 5 points Efficiency component 10 points 17 9
NYS Nursing Home Quality Initiative NHQI Overview Methodology Measurement Year Year of the data being used to calculate rank 2016 NHQI ranking is based on MDS data from calendar year 2015 Reporting Year Year that it is being reported 2016 NHQI Reporting Year is 2016 Affects deficiencies July 1, 2015 June 30, 2016 Affects timeliness of cost report submission Affects timeliness of flu vaccine information submission 18 NYS Nursing Home Quality Initiative NHQI Overview Methodology Thresholds Defined level of performance which you make or not Quintile Determined by the performance of all facilities Designed to assure distribution of facilities across all quintiles Moving target each year Goal needs to be to continually improve 19 10
NYS Nursing Home Quality Initiative Differences between CMS and NHQI Quality Measures Reporting period CMS is a rolling 12-month period NHQI is for the full 12-month calendar measurement period NYS specific adjustments Health inspections NYS regional cut scores for scoring Methodology for antipsychotic medication use for dementia Potentially avoidable hospitalizations Uses SPARCS data for all payors not just Medicare fee-for-service NYS state definition for potentially avoidable conditions 20 NYS Nursing Home Quality Initiative Quality Threshold Percent of contract/agency nursing staff used Used in 2016 quality initiative RHCF-4 Schedule O and Schedule 5 data % of contract/agency staff used RN s, LPN s & Aides only Difficult to obtain accurate reported information Quality initiative scoring: < 10% = 5 points > 10% = 0 points 21 11
NYS Nursing Home Quality Initiative Quality Threshold Percent of contract/agency staff used Calculation: Schedule O(1) Total Hours Paid (Sched O(1) Hrs Paid + Total Hrs Paid Sched 5) (RN s, LPN s & Aides) Ex: Contract Hours paid 5,900 = 1.5% <10% Total Hours paid 403,382 QI Score = 5 Points 22 NYS Nursing Home Quality Initiative New Quality Measure 2016 Calculation of staffing hours per day Replacing CMS Staffing Star rating 2016 Revision Use cost report data to reflect the actual hours provided by RN, LPN and Aides Use MDS data from calendar year 2015 to calculate expected hours Use New York state wide average to calculate case mix adjusted staffing rate (actual/expected X NYS average) Assigned to quintiles based on case mix adjusted staffing rate 23 12
NYS Nursing Home Quality Initiative Rate of Staffing Hours Per Day Utilizes RHCF and MDS data RHCF data Full-time hours worked for RN, LPNs and Aides (Schedule 5A line 051) Contract hours paid for RN, LPNs and Aides (Schedule O Quality) Total SNF Patient Days (Part 1 Patient Days Schedule) MDS data Hours and days at MDS 3.0 generated RUG III category CMS time staff measurement study 24 Calculation NYS Nursing Home Quality Initiative Rate of Staffing Hours Per Day RHCF data MDS data Total reported staffing hours Total reported SNF days = Reported data Total expected staffing hours (RUG adjusted) Total expected patient days (RUG adjusted) = Expected data Reported data Expected data X 3.5 Statewide Reported Average = Rate of Staffing Per Day * Per DOH NHQI Update. 25 13
NYS Nursing Home Quality Initiative Percent of Staff Turnover Benchmarking RHCF-4 Schedule P data Calculation (sample) Number RN, LPN & Aides (non contract and non per diem) Total End Quarter 1 160 End Quarter 2 150 End Quarter 3 155 End Quarter 4 160 Total 625 / 4 = 156.25 Terminations 24 / 4 = 6 * Per DOH NHQI Update. = 3.84 Staff Turnover Rate 26 NYS Nursing Home Quality Initiative Percent of Staff Turnover Per DOH data 2014 and 2013 Staff Turnover Rates 2014 Quintile 1 Quintile 2 Quintile 3 Quintile 4 Quintile 5 Statewide 11% 23% 36% 57% 1,231% 35.4% 2013 Quintile 1 Quintile 2 Quintile 3 Quintile 4 Quintile 5 Statewide 3.0% 5.4% 8.4% 12.3% 44.6% 8.4% * Per DOH NHQI Update. 27 14
Comparison of NHQI Quality Measures and CMI Elements Quality Measure CMI NHQI Pressure Ulcers Low Risk Residents who lose Control of Bowel & Bladder Falls with major injury Depressive symptoms Lose too much weight Self report moderate to severe pain Help with daily activities has increased Urinary Tract Infection Antipsychotic Medication Use for Dementia 28 SNF Quality Reporting Program (SNFQRP) IMPACT Act Requirements Reporting of Quality Measures across all Post Acute Providers Long Term Acute Care Hospital (LTACH) Inpatient Rehabilitation Facilities/Units (IRF) Skilled Nursing facilities (SNF) Certified Home Health Agencies (CHHA) Measures being developed are both clinical and claims based Clinical measures will use data from Provider specific assessments Skilled Nursing facilities - MDS 29 15
SNF Quality Reporting Program (SNFQRP) Comparison between SNFQRP and CMS 5 Star QM Data is collected on Medicare Part A FFS admissions only Measures will be based on a smaller population Residents may be at higher risk 30 SNF Quality Reporting Program (SNFQRP) SNFQRP FY 2017 Clinical Measures Only Percent with 1 or more falls with major injury while in SNF Part A stay Percent of residents with new or worsening Pressure Ulcers Percent with Admission & Discharge Functional Assessment and a care plan that addresses function Prevalence only No comparison of functional improvement between admission/discharge 31 16
SNF Quality Reporting Program (FY 2017 SNFQRP) Changes to the MDS effective October 1, 2016 Adding section GG to pick up functional assessment data Adding a new Part A Discharge (end of stay) MDS Report data for period of 10/1/2016 12/31/2016 Data must be reported by May 15, 2017 Potential 2% penalty reduction to market basket index for not submitting data Requires all data elements to calculate QM in 80% of MDS submitted Use of a (-) in any data element is considered not submitted 32 SNF Quality Reporting Program (SNFQRP) SNFQRP FY 2018 additional measures Drug Regimen Review with follow Up Includes both Medication reconciliation and Drug Regimen Review Includes those with clinically significant medication issues Requires response from physician by midnight of the next calendar day Medicare Spending per Beneficiary Successful Discharge to the Community Being reported as of April 2016 on Nursing Home Compare Potentially Preventable 30-day Post Discharge Readmission 33 17
SNF Value Based Purchasing Program (SNFVBP) Overview of SNFVBP Establishes a 2% withhold to Medicare Part A payments FY2019 Starts October 1, 2018 SNFs can partially earn back based on SNF VBP Measure score Earn back is between 50 70 % of total amount of reductions 34 SNF Value Based Purchasing Program (SNFVBP) SNF VBP Re-hospitalization Measure FY 2019 30 day all cause all condition Readmission Measure (SNFRM) Medicare Fee for Service claims based measure Risk adjusted co morbidities, specific diagnosis which have a higher readmission rate Long Hospital LOS indicating more complex care Does not include planned admissions 35 18
SNF Value Based Purchasing Program (SNFVBP) Methodology Financial implications Performance period will based on calendar year 1 st performance period will be January 1, 2017 to December 31, 2017 Quality Measures Improvement period will be based on 2 full calendar years prior 1 st improvement period will be CY 2015 and CY2016 Achievement score will be based on ranking on their performance year rate Score will be 0 100 points Bottom 25% = 0 Top 5% = 100 36 SNF Value Based Purchasing Program (SNFVBP) Methodology Improvement Score is based on improvement over the 2 year period Improvement range is based on difference between baseline period score and national benchmark If performance period score is improvement threshold = 0 points If performance period score is national benchmark = 90 points Is performance period score improvement threshold but < national benchmark then would be awarded points between 0 and 90. Re-hospitalization score is the higher of Achievement score or Improvement score 37 19
SNF Value Based Purchasing Program (SNFVBP) Proposed new measures FY 2020 Potentially Preventable re-hospitalization measure (SNFPPR) Medicare Part A claims based measure Only includes claims with Hospital diagnosis that are identified as preventable Inadequate management of chronic conditions Inadequate management of infections Inadequate management of other unplanned events 38 Know your Data Operational Strategies Managing Quality Measures Monitor your data on an ongoing basis Quality Measure Reports CASPER Key Operational Performance Measures Hospitalization/Re-hospitalization Data Discharge Data Assess your data for accuracy Focus on the key data elements that trigger the Quality Measures MDS data Claims data 39 20
Operational Strategies Managing Quality Measures Develop a CMI/QM Process Strategy Quality Measure CMI NHQI CMS 5-Star Rating Pressure Ulcers Low Risk Residents who lose Control of Bowel & Bladder Falls with major injury Depressive symptoms Lose too much weight Self report moderate to severe pain Help with daily activities has increased Urinary Tract Infection 40 21
Quality Outcomes and Data Collection Questions Joanne Jones jjones@loebandtroper.com (212) 697-3000, ext. 102 42 22