Ask the payment expert ... about MDS
Ask the payment expert ... about the observation stay loophole
A facility was recently cited due to not having enough staff that was indicated by the MDSs on hand. Is there a new staffing model being used?
The state may be using the MDS data and RUG levels to determine the “expected staffing” that compares the staffing levels to the RUGs levels. This is the same data that is used to calculate the facility rating for staffing as part of the Five Star rating system.
As of early February, during the survey, the facility submits CMS 671 and 672 forms. These determine the hours of staffing for RN, LPN and CNA (“Hours Reported”) staffers.
The Centers for Medicare & Medicaid Services has changed the process of how it is gathering that information, so watch for upcoming Five Star updates (See pages 1, 4). CMS calculates the RUGs staff time values for the residents in the facility at the time of the survey, which is the “Hours Expected.”
In other words, they apply the staff times for RNs, LPNs, and CNAs according to the present RUGs level of each resident. A formula calculates “Hours Adjusted” as follows: Hours adjusted = (Hours Reported/Hours Expected) * Hours National Average.
The present national average for total staffing (RN, LPN, CNA) is 4.0309 and for RNs is 0.7472. More information on this calculation can be found at http://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/CertificationandComplianc/Downloads/usersguide.pdf, starting on page 6.
Basically, CMS is correlating the amount of staff you have in your facility to the RUG levels of the residents they care for. So, in effect, it is an acuity-based staffing methodology.
You can do this yourself. We typically recommend that an operator run this type of formula on a monthly basis. Some facilities do it weekly.