Guest Columns

CMS sneaks a trick in with its treats

Steven Littlehale
Steven Littlehale

While October 1st brought its usual changes this year with the implementation of the Fiscal Year 2016 Final Rule updates to Market Basket adjustments and Medicare payments, we also had some additional “treats” included: value-based purchasing and the identification of the measures to be used in the Centers for Medicare & Medicaid Services' Quality Reporting Program.

In addition, October 1 brought skilled nursing facilities the “treats” of voluntary electronic reporting of staffing levels through the Payroll-Based Journal and the proposed rule outlining new, significant changes to the Conditions of Participation in the Medicare and Medicaid programs.

Perhaps the biggest treat of all? Why ICD-10, of course!

With all of these things happening at the same time, no wonder providers were likely too distracted to notice the latest “trick” by CMS: changes to the Quality Measures. That's right, after effectively soaping our windows with all the other changes, CMS slipped in some changes to QMs, and three-quarters of them impact the QMs that are part of the Five Star rating in the quality measure domain!

Starting this month, the Influenza Long Stay and Short Stay measures will be calculated only once a year, with the target assessment coinciding with the flu season determined to be October 1 through March 31. For Short Stay QM New or Worsening Pressure Ulcers, Long Stay Catheter and Long Stay Pain, there has been a change to how the covariates (risk adjustments) are counted.

Prior to the change, residents that had assessments with missing, dashed or essentially null data for the risk adjustment items (covariates) were excluded from the QM calculation. Now, they are counted. So what does that mean? Well, if that was all CMS changed, it would be a treat to providers because their rates would improve. But rather than changing just the covariate count, CMS also adjusted the coefficients used in the overall calculation. The result? Negligible changes to the rates for those three QMs — perhaps that's also why there were no ghostly howls heard when the new User's Manual was released.

The biggest impact appears in the Short Stay Influenza measure. By changing the target assessment timeframe to the designated influenza season (October 1 through March 31), there is almost a 10% improvement in Short Stay Influenza rates. So perhaps there is a treat in the changes after all.

But before you decide that CMS has no other tricks up its sleeve, you should know that on a recent CMS call with provider stakeholders, the agency announced that in 2016 there are plans to rebase the QMs to “raise the bar” of quality in the SNF provider community.

Sounds like we'll need to wait to see if that treat leads to tooth decay. Please floss.

Steven Littlehale is a gerontological clinical nurse specialist, and executive vice president and chief clinical officer at PointRight Inc.

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