MDS Case Mix Reporting

OMPP, via Myers & Stauffer, notified facilities last month of a change in the MDS Case Mix Reporting system.  The notice (click here) provided instruction for each facility to provide M&S with contact and computer information for designated users for each facility.  IHCA contacted M&S to inquire about the ability for corporations to have a login that would access all facilities within that corporation.  To date, OMPP has replied that a third corporate designated user will be permitted, but had not clarified how that user is to sign up or whether that user will be able to access all corporate facilities via a single log-in.  The deadline to submit this information to M&S has passed, but we will inform the membership asap on any changes via the Payment/Reimbursement Committee email list.

Indiana Medicaid Rate Update

The Indiana Office of Medicaid Policy and Planning (OMPP) has started issuing July 1, 2014 rate letters via its contractor Myers & Stauffer.  The rate component medians have been released and can be found by clicking here.  M&S is due to release the other LTC Information System reports on the 7/1/14 Rate Effective Date in the next week or so.  This includes information on the second year of facility performance in the Value Based Purchasing add-on (i.e. the Total Quality Score add-on).  IHCA is also hearing early rumblings that some facilities with Special Care Units (SCU) that have received 7/1/14 rate letters are seeing SCU add-ons in excess of what they expected.   IHCA urges facilities to double check their submitted cost report information against their rate letter, and eventually the M&S SCU calculation file that will be posted on the M&S LTC website this month.

In other Indiana Medicaid rate news, IHCA is expecting a decision from OMPP concerning the transition to RUGs IV this month.   There has been months and months of debate on whether such a transition should be to the 48 or 64 grouper, with IHCA and its members advocating for the 48 grouper.  IHCA has continued meeting with agency officials and most recently proposed a cost-neutral solution to the agency to that any cost to the State for transitioning to a 48-grouper system would be absorbed by redistributing gains and losses more equitably.  Beyond this issue are the issues of maintaining the SCU add-on, which two years ago was floated to be eliminated in order to in-part pay for the costs of moving to a 48-grouper, and whether or not to re-group Medicaid therapy residents at the end of therapy based on the reference MDS assessment already on file.  IHCA has argued against elimination of the SCU add-on and has advocated for a common sense approach to the end of therapy re-grouper, which at this point is not to do it since it costs the State money to do and derives no policy objective.

To learn more on these issues, contact Zach Cattell at 317-616-9001 or zcattell@ihca.org or particulate in our monthly Payment/Reimbursement Committee conference calls (contact Zach for this as well).

CMS Transmittal Related to Appendix PP

CMS issued transmittal 127 on November 26, 2014.  This transmittal updates Appendix PP (Ftags and surveyor guidance) and contains no new information.  All material included in this transmittal was issued as policy or as advance guidance between 2003 and May 2014.  Except for information related to four tags (F155, F309, F322, F329) all of this material was issued as an advance copy on July 3, 2014.  The additional language at the four tags not in the July advance copy and the original advance release information follows:
•    F155 relates to Advance Directives (issued as an advance copy on September 27, 2012 and revised March 8, 2013);
•    F309 relates to care and services for individuals with dementia (issued as an advance copy on May 24, 2013);
•    F322 relates to Naso-Gastric Tubes (issued as a revised advance copy on March 8, 2013); and
•    F329 relates to Unnecessary Drugs (issued as an advance copy on May 24, 2013).

OSHA Reporting Requirements to Change January 1, 2015

Our national association AHCA/NCAL has provided this summary of the OHSA final rule concerning Occupational Injury and Illness Recording and Reporting Requirements.  Effective January 1, 2015 employers must report an expanded list of injuries to OSHA and revises the requirements for when an employer must report work-related hospitalizations.  Please review the above document for more details.

MSD Focused Surveys

CMS issued Survey & Certification Memo 15-06-NH (click here for the memo) on October 31st that announces an expansion of the 5-state pilot program that was focused on MDS coding practices.  The pilot program found deficiencies in 24 of 25 facilities’ MDS coding practices that had a negative impact on the ability of surveyors to identify deficiencies in patient care.  Findings included inaccurate staging and documentation of pressure ulcers, problems with classification of antipsychotic drugs, and poor coding concerning use of restraints.  This pilot project followed a 2013 report from the OIG that indicated found issued with MDS information as the OIG reported on issues concerning NF care planning and discharge planning.

To be coupled with the MDS surveys will be a staffing surveys in order for CMS to validate what is now reported during the annual survey on the CMS-671.  Staffing levels will be assessed during the expanded MDF “Focused Surveys”.

The Focused Surveys will begin in early FY2015, which is any time now.  CMS will work with States to determine how many surveys will be conducted, and when, as well as whether specific facilities should be surveyed.  IHCA understands that Indiana will have 12 facilities as part of this expanded program.  A survey protocol and tool is also being developed.  Record review and interviews will be utilized in the surveys.

Residential Care Facility Citation Update

In October 2014 the ISDH issued 31 Deficiency tags and 8 Offense tags to Residential Care Facilities.  The leading tag in October was Tag 241, an Offense tag, concerning the failure to have physician ordered medications administered by licensed nurses or QMAs.  This citation is often cited by the ISDH, being cited in each month of 2014 except for February.  Tag 247, a Deficiency, was cited three times in the month concerning the documentation of errors in mediation administration and notification to the physician of  any such error when there is actual or potential harm to the resident.  A usual high-frequency tag, Tag 273 concerning maintaining food preparation and service areas in accordance with state and local sanitation standards, was only cited 4 times in October.  Lastly, hand washing appears to continue to be an issue as three facilities were cited Tag 414 for staff failure to wash hands after each resident contact.

Click here to review a summary of October’s Residential Care Facility Offense and Deficiency citations.

ISDH IJ/SSQC Update

The ISDH cited one tag in October that was at the IJ and SSQC level.  That tag, F329, was cited for failure to ensure an anticoagulant that had been discontinued per the physicians order was actually discontinued, and that accurate documentation of MARs and Physician Order Sheets were accurately reflecting physician orders.  The resident had been placed on Coumadin therapy, with corresponding orders for P/INR tests, to manage deep vein thrombosis as of April 21, 2014.  The physician discontinued the medication regimen on May 12, 2014 and the medication was not administered in May thereafter.  In June the Physician Order Sheet included an order for Coumadin for the resident, however the RN in charge of checking orders caught the error and crossed it off per the physician’s order.  In July, August and September the Physician Order Sheet contained the same order for Coumadin, but in each of these months the nurse did not catch the error and according to the MARs the Coumadin was administered.  The error was caught in September when the DON was reviewing lab results, at which time the resident was experiencing critically high PN/INR values resulting in administration of Vitamin K and ongoing monitoring for bleeding issues.  Investigation at the facility found that Coumadin flow sheets were not being maintained in July and August, and the pharmacy indicated that they reported no discontinuation orders for this medication.  The IJ was lifted when new staff was assigned to review Physician Order Sheets, random audits were performed for the sheets, and all staff were in-serviced concerning Physician Orders Sheets and monitoring for effects of medication.

Please click here to access the October 2567 and the IJ/SSQC 2014 Summary.