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SNF QRP Non-Compliance Letter Response

In the Skilled Nursing Facility Prospective Payment System Final Rule 80 FR (46427 through 46429) the Centers for Medicare & Medicaid Services (CMS) finalized the Skilled Nursing Facility (SNF) Quality Reporting Program (QRP) requirements.

Any SNFs found non-compliant according to the quality reporting requirements will receive a letter of non-compliance through the Quality Improvement and Evaluation System Assessment Submission and Processing (QIES-ASAP) system, as well as through the United States Postal Service. (source: CMS)

You need to take action if you receive a letter from the QTSO Help Desk stating that your facility has not submitted complete data for one or more SNF QRP measures.

Your facility will lose 2% of the overall Medicare Part A reimbursement for one year unless you can effectively complete a reconsideration process.

Recommended Actions For Developing a Reconsideration Response:

  1. Identify what caused the missing data.
  2. From the CASPER website:
    • Run the Review and Correct reports for the time frame indicated in the letter 
      • Identify which resident stays are included in the quality measure(s)
    • Run the MDS Validation reports for the same time frame 
      • Identify any warnings or rejected MDSs for those residents
  3. Some common issues that cause data to be missed:
    • Using a dash (-) in any Performance area of MDS Section GG.
    • Failing to code at least on goal in Section GG of a 5-day MDS.
    • Failing to code a fall in MDS Section J.
    • Failing to correctly code pressure ulcers in MDS Section M.
    • Failing to code “yes” in MDS A0310H whenever a Discharge MDS is completed (return anticipated/return not anticipated, planned/unplanned) for a Medicare Part A stay.
    • Failing to complete a stand-alone Medicare PPD End of Stay MDS when a resident’s Medicare Part A stay ends, and the residents stay in the facility for more than 24 hours after the Medicare last covered day.
  4. Review the MDS and make corrections if possible. Once a resident has been discharged from the facility, it is not allowed to open an MDS that was missed during the stay.
  5. Contact the QRP Reconsideration Help Desk – SNFQRPReconsiderations@cms.hhs.gov.

Contact us to discuss your facility’s specific needs.

 

Author:
Karolee Alexander,
Director of Reimbursement and Clinical Consulting,
Pathway Health