Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare
CMS posted the updated Five-Star Quality Rating System Technical Users Guide (29-pages) this past week. The updated State-Level Health Inspection Cut Point Table (4-pages) was also posted.
July 2020 Revisions: Temporary Changes due to COVID-19
Staffing Rating Changes:
Under the COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers, CMS waived the requirements at 42 CFR 483.70(q), which required nursing home providers to submit staffing data through the Payroll-Based Journal (PBJ) system. Because of the waiver, many facilities did not submit staffing data by the May 15, 2020 deadline, and thus, CMS will not be able to update the PBJ staffing measures and staffing domain star ratings at the next regularly scheduled update in July 2020. Therefore, staffing measures and ratings will be held constant and based on data submitted for October – December 2019.
In addition, CMS recognizes that the waiver of the requirement prevented some facilities from improving their rating from their previous quarter’s submission. Specifically, facilities whose staffing rating was automatically downgraded to one-star due to missing the deadline for the previous submission, or for reporting four or more days in the quarter with no registered nurse, will not have the opportunity to correct and improve their staffing rating since the ratings will be held constant. Therefore, CMS will remove the one-star staffing rating downgrade, and instead, these facilities will have their ratings temporarily suppressed. Their staffing ratings will show “Not Available” for July, August, and September 2020.
Quality Measure Rating Changes:
Similar to the staffing data waiver, CMS waived requirements at 42 CFR 483.20 related to the timelines for completing and submitting resident assessment (minimum data set (MDS)) information. This information provides the underlying data used to calculate quality measures used on the Nursing Home Compare website and in the Five-Star Quality Ratings System. CMS believes that data from resident assessments conducted prior to January 1, 2020, can still be used to calculate quality measures (QMs). However, CMS is concerned that data from resident assessments conducted after January 1, 2020 were impacted by the waiver and the public health emergency. Therefore, beginning July 29, 2020, quality measures based on the data collection period ending December 31, 2019 will be held constant. Quality measures that were based on a data collection period prior to December 31, 2019 (e.g., ending September 30, 2019); however, will continue to be updated until the underlying data reaches December 31, 2019. We note that CMS is not holding the quality measure ratings constant, as a facility’s quality measure rating can still be updated by a quality measure with underlying data that is earlier than December 31, 2019.
The MDS-based QMs will continue to cover 2019Q1 – 2019Q4. Four of the claims-based measures (long-stay and short-stay hospitalizations and ED visits) will be updated and will cover the time period January 1 – December 31, 2019. The short-stay QM, rate of successful return to home and community, will continue to cover October 1, 2016 – September 30, 2018.
Health Inspection Rating Changes:
Since the Nursing Home Compare (NHC) refresh in April 2020 and until further notice, the health inspection domain of the rating system is being held constant to include only data from surveys that occurred on or before March 3, 2020. Results of health inspections conducted on or after March 4, 2020, will be posted publicly, but not be used to calculate a nursing home’s health inspection star ratings.
CMS will continue to monitor inspections, including the restarting of certain inspections (i.e., surveys) per CMS memorandum QSO-20-31-ALL. CMS will restart the inspection ratings as soon as possible and will communicate any changes to stakeholders in advance of updating the Nursing Home Compare website.