Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare
CMS posted QSO-20-28-NH late in the day on Friday. Here’s the Memorandum Summary for this 15-page notification:
A couple of the subjects in this notification speak to surveys, quality measures and staffing domains (MDS and PBJ). I’ve highlighted key verbiage in both:
“Due to the March 23rd targeted inspection plan, there is a great shift in the number of nursing homes inspected, and how the inspections are conducted. This would disrupt the inspection domain of the Nursing Home Five Star Quality Rating System because many nursing homes that would normally be inspected, will not, thereby over-weighting and impacting the ratings of those facilities that are inspected. This could then potentially mislead consumers. Therefore, we (CMS) will temporarily maintain and hold constant the health inspection domain of the rating system. Specifically, results of health inspections conducted on or after March 4, 2020, will be posted publicly, but will not be used to calculate a nursing home’s health inspection star ratings. This action will start with the scheduled update to the Nursing Home Compare website on April 29, 2020. The surveys will be posted through a link on the front page of the Nursing Home Compare website in the upcoming months (as the survey data is finalized and uploaded).”
“Separately, to help facilities focus their efforts on protecting their residents from COVID-19, CMS has waived timeframe requirements for submitting resident assessment data (minimum data set (MDS)) and staffing data (Payroll-Based Journal (PBJ)) by certain deadlines. However, these waivers related to the timing of MDS and PBJ data submissions will not impact the updates to the quality measures and staffing domains that will be used for the April update of the rating system on April 29, 2020, because the underlying data for these domains is based on time periods that occurred prior to the COVID-19 crisis (e.g., prior to the Secretary declaring a Public Health Emergency on January 31, 2020). While these waivers will not impact the upcoming April update, CMS is monitoring the situation closely and is prepared to make appropriate adjustments to future updates in order to ensure facilities’ ratings are fair and accurate, while still providing valuable information to consumers. CMS will communicate any changes with the stakeholders as soon as possible.
Nursing Home Staff and Resident Information Nursing homes are required to report direct care staffing information through the PBJ system (per 42 CFR 483.70(q)). To date, this information has been used to calculate staffing measures and staffing ratings for each nursing home. However, this information is also capable of supporting our response to the COVID-19 pandemic. Specifically, we are releasing information that shows the average number of staff each nursing home has onsite, each day (nursing staff and total staff), and aggregated by state and nationally. See section 2.3, Table 1 of the PBJ Policy Manual for a list of direct care staff this includes. This also include facilities’ average census per day and total beds. For example, nationally, nursing homes have, on average:
- 41 different nursing staff and 60 different total staff onsite, each day.
- An average daily census of 87, and 107 total beds.
The information is based on data submitted for 2019 Calendar quarter 4 and may not reflect the actual conditions in facilities at the point in time used. However, we believe this information can be used to identify approximate facility needs, and help support local, state, and federal agencies’ response to preventing and controlling the transmission of COVID-19. For example, this could be used to help state agencies where, and how much, personal protective equipment (PPE) and testing should be directed within their state. States can also work with facilities on their PPE needs based on facilities’ use of the Centers for Disease Control and Prevention PPE Burn Rate Calculator.
Information on nursing home census is already available on the Nursing Home Compare website and in downloadable files. However, this is the first time information about the number of individual staff each facility has been made available. This action bolsters CMS’ response to COVID-19 and reinforces our commitment to transparency. The (2019 4th Quarter) information is available here.”
Please review the entire document – pages 4 through 15 is the FAQ section.