Succeeding Under CMS’s New Quality Measures: Three Steps for SNFs to Follow

On Wednesday, CMS released data on 5 new quality measures under the Skilled Nursing Facility (SNF) Quality Reporting  Program (QRP). QRP was born out of the 2014 IMPACT act and it is unique in that unlike other SNF quality measure programs, the QRP program requires the reporting of quality measures that can be calculated across care settings using standardized data elements nested within each care setting’s assessment instrument. Whereas previously quality measures for SNFs could only be used to compare one SNF to another SNF, the QRP measures can be used to compare a SNF to inpatient rehabilitation facilities (IRFs), long-term care hospitals (LTCHs), and home health (HH). Within the context of CMS’s directive to acute providers to discharge patients to the lowest cost post-acute care setting that’s clinically appropriate, the QRP measures may result in hospitals and payers changing practices of SNF utilization relative to other care settings.

Here are 3 things SNFs can do to mitigate against decreased referrals and other potential negative impacts.

Step #1: Understand the New QRP Measures and How the SNF’s Action Impacts Performance on Each

The first three measures are MDS assessment-based, the latter two measures are claims-based.

  • Percent of Residents or Patients with Pressure Ulcers that are New or Worsened (Short-stay). Pressure ulcers can be avoided if a provider has adequate preventative care in place, such as proper nutrition, repositioning regimen, and padding or cushioning designed to prevent pressure ulcers.
  • Application of Percent of Long-Term Care Hospital (LTCH) Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function. SNF nursing staff should assess a patient’s physical function both at the beginning of the stay and at discharge. Strong assessment and goal-setting will help patients maintain and improve their physical well-being and ensure that they have the necessary supports in place to return to the community.
  • Application of Percent of Residents Experiencing One or More Falls with Major Injury. A common cause of hospitalizations and ED visits among SNF patients is an injury resulting from a fall at the facility. SNFs should ensure that their facility is free of environmental hazards and that patients with mobility problems have adequate support.
  • Medicare Spending Per Beneficiary. This measure represents the relative Medicare spending for a provider’s average episode of care compared to how much Medicare spends on an episode of care across all SNFs nationally. Providers with a ratio greater than 1 are spending more than the national average; providers with a ratio less than 1 are spending less than the national average. This measure is an important resource use indicator that CMS put forth to support efforts to provide more efficient care.
  • Discharge to Community. Successfully returning home is a common goal for short-stay SNF patients. Providers can help patients meet this goal by providing appropriate care and rehab during their stay and engaging patients and families in discharge planning.

Step #2: Review Performance Against Peers

SNFs should review the QRP measures and first compare themselves to other SNF providers in their referral market to determine which measures they are performing well on and which measures require improvement. SNFs can now find their measure posted on Nursing Home Compare. After a SNF compares themselves to other SNFs in their market, they should also begin to think about how they compare to other types of PAC providers in their market. When hospitals and payers are making patient referrals, they’re not just going to look at the SNF’s performance in isolation, rather they’re going to look at the group of regional PACs that they can discharge the patient to and evaluate which ones give the patient the best chance of a positive outcome. To understand how a SNF compares to PAC providers in other care settings they’ll have to view data on the LTCH, HH, and IRF CMS compare websites.

Step #3: Develop a Plan to Address Deficiencies

CMS will release QRP data on a regular basis, so if SNFs assess their performance relative to the measures and their peers and identify deficiencies, there is an opportunity to rebound in a timely way, perhaps preempting a loss of referrals.

A Final Note: The 6th (Unpublished) Quality Measure

In a surprising turn of events, CMS opted not to publish an additional measure under consideration—Potentially Preventable 30-Day Post-Discharge Admissions—noting that more testing is necessary to ensure that this measure would paint an accurate picture of provider quality. SNFs need to stay tuned in to CMS announcements as this measure will likely be introduced in the near future and would have a major impact.

To learn more about navigating the post-acute space amidst new regulatory and payment changes, register for our upcoming webinar, Moving the Needle on SNF Quality Measures.