The Centers for Medicare & Medicaid Services made one thing clear when it issued its newly proposed nursing home pay rule last week: Promoting nursing home quality improvement is driving policy formation. 

In addition to publishing proposed pay rates and extensive changes to its value-based purchasing program in the fiscal 2024 SNF Prospective Payment System draft, the agency also laid out extensive changes to its quality reporting program.

Under the QRP, facilities are required to track and report specific data through MDS and other systems. Those that don’t submit enough comprehensive data are docked 2% of their annual Medicare pay.

In the rule issued last Tuesday, CMS proposed the adoption of three new measures, the removal of three measures and the modification of another. In addition to changing the measures themselves, CMS is proposing to increase the amount of information required to keep full payments. Starting in fiscal 2026, providers will have to submit 100% of required quality measures for 90% of patients, up from the current 80% of patients.

Adding more reporting requirements presents another challenge to many providers, most of whom are struggling to fill frontline care positions — as well as assessment professionals  who are often responsible for submitting quality metrics.

“We have to keep in mind that more measures don’t necessarily mean better care,” said Melanie Tribe-Scott, BSN, director of quality innovations at Zimmet Healthcare Services Group. “It’s really the quality of the measure we’ve got to look at, and things change over the years so the measures should change too.”

All quality measures are published online on Care Compare, but only two QRP measures  (pressure ulcer rates and successful return to home or community) are currently factored into Five-Star quality measure score. Tribe-Scott anticipates that won’t change quickly with any of the proposed new measures, the earliest of which would launch in fiscal 2025.

The first proposed addition is a new Discharge Function Score measure, which would capture the share of SNF residents who meet or exceed an expected discharge function score. It will use mobility and self-care items already on the MDS. This measure has also been proposed as an addition to the CMS nursing home value-based purchasing program.

In effect, the measure replaces two other related measures that CMS is proposing to retire. But, noted Tribe-Scott, that still leaves providers with three discharge function measures to track and report.

And it’s a dual-purpose measure that providers could find challenging to shine in, observed Melissa Brown, chief operating officer at Gravity Healthcare Consulting.

“The Discharge Functional QRP Measure is based on whether the resident met or exceeded the expected functional outcomes, based on their specific clinical indicators including admission function score, age, and clinical conditions. This measure was selected, as opposed to whether the resident met the discharge goal selected on the MDS, because this would reduce the ability to ‘game’ the system, as CMS states in the Proposed Rule,” she told McKnight’s Long-Term Care News Friday.

Satisfied customers?

Tribe-Scott and Jodi Eyigor, LeadingAge’s director of nursing home policy, both view a proposal to add a Core Q: Short-stay customer satisfaction measure as a move that could benefit providers.

“It’s a positive that we have a customer satisfaction measure that would be included. That’s something that we have heard from our members for many years that they wanted,” Eyigor said last week. 

Added Tribe-Scott: “This is one that I feel is really going to benefit the provider. This is something we should probably already be doing on some level.”

The measure will assess how many discharged residents are satisfied with their stay over six months, using a standardized, four-question survey.

“It’s going to help the facility gauge their customer satisfaction. As we all know, that’s a huge part of marketing to our consumers,” Tribe-Scott said. “What I also see is this could really potentially decrease our 30-day readmissions because the resident will be more apt to be in contact with the facility to tell them if they’re having issues.”

But Eyigor offered one caution about the proposal.

“CMS says to have this CORE Q, you have to contract with an independent, CMS-approved vendor,” she said. “Independent vendor: That’s a great idea because we want to be sure this is valid data. However, this is going to cost you some money.”

Vaccination measures

CMS also has proposed the adoption of a COVID-19 vaccine measure for “up-to-date” patients beginning in fiscal 2026; it would be collected through a new MDS element but providers conceivably also would still report vaccines through the NHSN portal to comply with other requirements. The agency also proposed modifying the current COVID Vaccination Coverage Among Healthcare Personnel measure beginning in fiscal 2025 to capture up-to-date shots, rather than just the mandated primary vaccine series.

“We’re not going to see this go away,” Tribe Scott. “We kind of know that; it’s been three years now. … We’re going to continue to have to report on these.”

She added it would be important to follow Centers for Disease Control and Prevention definitions of “up-to-date.” The measure could change as vaccine requirements and availability do, especially if COVID shots eventually move to a seasonal schedule similar to that for flu shots.

Want to learn more about possible upcoming quality reporting changes? Check out the McKnight’s Daily Update newsletter or on Wednesday for a podcast in which expert Melanie Tribe-Scott shares additional insights.