Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

I had the privilege of attending the 2022 AAPACN (American Association of Post-Acute Care Nursing) conference this week. I’m also a proud ‘99er, having been a member of the association since its “birth” in 1999.

Officials from CMS are always invited to this annual conference, and they are always gracious and giving with their time and information. We are very appreciative for this opportunity to hear directly from them. (Thanks Ellen, Evan, and John!)

I want to provide you with some take-aways from the CMS portion of the conference:

  • CMS could not discuss the FY2023 SNF PPS Proposed Rule – they never can during the rulemaking process. If you’re not aware that this proposed rule has been posted (and today published in the Federal Register, read this
  • There will be a new version of the MDS 3.0 Item Set implemented on October 1, 2023. Not this October – next October. CMS is adjusting and finalizing work on v1.18 that was intended for implementation on October 1, 2020, but the pandemic interfered with that version. We’ll continue to encode and transmit v1.17.2 through September 30, 2022; same with utilizing the October 2019 RAI User’s Manual for proper coding. The v1.18 draft will be posted “by end of summer if not sooner.” 

Along those same lines, CMS was asked if Section G would be going away with v1.18.  Because of the rulemaking process, CMS cannot respond to that question but did note that the goal of the future MDS Item Set was to eliminate double coding.

  • Everyone’s asking about the QHS waiver – Qualifying Hospital Stay. This waiver is still in effect and can be used as appropriate. CMS is evaluating the waiver and currently has no specific timeline for it to expire. CMS told us that advanced notice of the expiration of the QHS waiver was “highly likely.”  If you’re not aware of the QSO posted on April 7, 2022 regarding waivers expiring in 30 and 60 days, this blog is for you.

On the subject of waivers, please note that by October 7, 2022, all temporary Nurse Aides must be certified. Don’t wait to get this process started.

Also, CMS was asked if there would be post-COVID audits on the QHS waiver (you know what this answer will be don’t you!). We were told that CMS audits will focus on the need for skilled care and provision of skilled services. (Tip: you may want to identify your facility’s use of the waiver to see if you may have any issues.)

  • LTCFs will transition to the iQIES system for submission of MDS in January 2023. Other PAC providers have been using iQIES for some time now. LTC is next to move from QIES to iQIES. More information will be coming, including timelines and FAQs. CMS told the group that this change will not impact the facility’s workflow and that MDS files will continue to be submitted in .xml format. CMSNet will be retired. This is a replacement of old technology.

New user IDs will be needed. CMS encouraged users to not wait until the last minute to obtain their new user ID. Transitioning to the iQIES system will eventually make additional reports available to users. Keep watching (BNN will keep you posted as well) for more information on this transition.

  • CMS praised LTCFs for “doing a good job with staff vaccination,” noting the agency is watching vaccination rates very closely. Kudos to all of you – keep up the good work to increase vaccinations and boosters!
  • CMS noted that the NH lockdowns early in the pandemic were the “2nd most heartbreaking” element we’ve experienced, the 1st being the number of resident and staff deaths. CMS “promised” to never restrict such visitation again.
  • CMS notes that the #1 complaint the agency receives involves involuntary discharges from the LTCF. Facilities are urged to follow the steps for this process very carefully.
  • Staffing in LTCFs has been a problem for a very long time – it is NOT new due to the pandemic. The pandemic highlighted this shortage. CMS acknowledges that as should we in the LTC industry. The staffing issue is multifactorial in nature. CMS encourages facilities to review the FY2023 SNF PPS Proposed Rule as they are requesting information from stakeholders (YOU!). CMS wants your feedback on the issue of staffing. Provide suggestion as well as information. As an industry, we have ideas on how to improve this issue so share them via your comments to the proposed rule.
  • CMS spoke to the backlog of surveys. States are starting to get back up to being onsite for surveys and are finding some serious issues such as an increase in antipsychotics, weight loss, depression, pressure ulcers, reduced physical functioning, etc. We were reminded that if you’re using agency staff, they too must be trained and competent so don’t just bring them in and set them loose. You’re responsible for the care they provide while under your roof.

CMS is also concerned about the increasing/inappropriate diagnosing of schizophrenia in the elderly population. The agency will be watching for the presence of a comprehensive medical/psychiatric assessment to verify the presence of such a diagnosis and thus the use of an antipsychotic. CMS reminded us that it is very rare for an elder to have a new diagnosis of schizophrenia.

On the subject of CMS wanting stakeholder feedback, here’s another topic to speak to. Special Focus Facilities have 2 distinct issues. Some facilities languish on this SFF list for a very long time – no progress in needed improvements while others who have graduated off the SFF list are regressing, and care is suffering. Please provide any/all feedback you have on this important subject.

  • PBJ was another topic addressed. Some facilities are switching PBJ vendors which results in new staff IDs being created. As a result, Care Compare Five-Star ratings are showing turnover where turnover doesn’t actually exist. Please follow the instructions to link staff. This blogcan help you with that. Remember that staff turnover will be part of the Five-Star Rating System this July.
  • Infection Preventionists. CMS reminded facilities to take advantage of infection prevention and control opportunities – there is no shortage of training, and a lot of these opportunities are free of charge. Project Firstline is one of the most recent programs; STRIVE is another. 

That’s all I have for updates at this point in time. Please continue to watch the BNN Blog for more information. Click on the Subscribe button (left side of landing page) to automatically receive email notification when new blogs are posted. Use the Search feature to find specific information.