New CMS Memos – Leadership “Need to Know”

We all know change is an inevitable, new reality in post-acute care. Our industry continues to transform utilizing data (organizational and public) as a determining factor for consumers, strategic partners, and regulators. In the past few weeks, the Centers for Medicare & Medicaid Services (CMS) has published three new QSOs that directly impact providers.

After reviewing the memorandums, I developed a few tools for leaders to help gain a better understanding of the changes, as well as key steps to help prepare your team and your organization.

Below is a brief summary of the CMS announced changes. Click Here for Detailed Description.

April 2019 Improvements to Nursing Home Compare

In summary:

• Star Ratings – The freeze on Health Inspection Star Ratings will be lifted effective April 2019 impacting your organization’s overall star rating.
• Quality Measure Domains – New Quality Measure Domains and changes impacting your Five Star rating will go into effect.
• Staffing Domain Improvement – Thresholds for staff ratings will be adjusted. It’s important to note the threshold for the, “number of days without a registered nurse (RN) onsite,” that triggers an automatic downgrade to one star, “will be reduced from seven to four days.”
• CMPs – It’s also important to note that the moratorium on CMPs will be lifted as of April 1 in alignment of the Health Inspection Star Rating lift as indicated above.

Revision to Appendix Q – Immediate Jeopardy (Core Appendix Q)

Clarification on how surveyors issue Immediate Jeopardy (IJ) citations has been released by CMS. There is updated interpretive guidance related to noncompliance as well as specific differentiators that are important for leaders to understand:

• Likelihood vs. potential
• Noncompliance vs. culpability
• Psychosocial harm
• Key components of Immediate Jeopardy

Download the Leader’s Guide: Core Appendix Q Overview, which will assist you and your team in understanding the changes impacting providers.

Leaders should review the online basic Core Appendix Q training on the Integrated Surveyor Training Site which provides a comprehensive review and understanding of the changes.

Enhanced Oversight and Enforcement of Non-Improving Late Adopters

CMS has identified approximately 1,500 facilities that have not improved their antipsychotic medication utilization rates. CMS has heightened its regulatory focus on those organizations, and they will be subjected to enforcement remedies for noncompliance.

While these memorandums are not a surprise to us, there are key tactics you can take to prepare your team for the impending changes. Download this QuickTip Guide for a comprehensive look at the upcoming changes.

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