January 2023 Additions to the OIG Work Plan 

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

Two additions to the OIG Work Plan for LTC caught my eye:

Assessment of CMS’s Early Use of Payroll-Based Journal Data To Improve Enforcement of Nursing Home Staffing Standards:

In October 2022, CMS began to provide State Survey Agency surveyors (State surveyors) with extracts of Payroll-Based Journal (PBJ) staffing data for use in annual nursing home certification surveys (also known as “inspections”). CMS instructed State surveyors to use this data to investigate specific instances of noncompliance with hourly staffing standards (for example, the requirement to have a registered nurse on duty for a minimum of 8 hours per day). Additionally, CMS instructed State surveyors to review PBJ data for indications of whether a nursing home has met the requirement to have sufficient staffing. Our objective is to assess the early results of CMS’s strategy to use PBJ data to improve the enforcement of Federal nursing home staffing standards by State surveyors. We (OIG) will review CMS’s plan for monitoring the success of the strategy and explore State surveyors’ experiences with using the data in their surveys.

Assessment of the Special Focus Facility Program for Nursing Homes:

CMS established the Special Focus Facility (SFF) program to improve care in the poorest performing nursing homes. CMS and State survey agencies conduct increased oversight of nursing homes in the SFF program by surveying these facilities twice per year-about twice as often as required for other nursing homes. In October 2022, CMS updated the SFF program to reduce the amount of time a nursing home spends as an SFF and increase the number of nursing homes that go through the program. This study will evaluate CMS’ s and State survey agencies’ implementation of the SFF program, including implementation of the October 2022 updates to the program. In addition, this study will identify factors that have aided graduated SFFs with sustaining quality improvements and assess the extent to which CMS and States incorporate these factors into the SFF program.