In 2009 the Indiana Division of Aging (DA) assembled a Clinical Expert Panel to develop the current Value Based Purchasing (VBP) add-on to the NF Medicaid rate. The VBP add-on is comprised of the Report Card Score, staffing retention and turnover measures, and nursing hours per resident day. The DA has announced that is reconvening the Clinical Expert Panel to examine changes to the VPB components with a goal of implementation of those new components on July 1, 2016. As previously reported the additional components may be clinical outcomes measures like the MDS QI/QMs and results from satisfaction surveys of residents, families, and staff that have been conducted and will continue in the coming years. Other measures that look at rehospitalizations or preventable errors may also arise in the discussions.
IHCA will be engaged in this process as the next iteration of VBP is developed. To date, three IHCA members have agreed to serve on the panel. Mary Pankey, Director of Clinical Operations with CarDon & Associates, Teresa Wallace, Chief Nursing Officer with TLC Management, and Martha Herron, VP of Clinical Services with American Senior Communities. IHCA expects one more person from the membership to be appointed to the panel. Works is expected to begin sometime in January or February.
Wednesday, January 7, 2015
Indiana Medicaid Presses to Transition to RUGs IV 66 Grouper Effective July 1, 2016
The Indiana Office of Medicaid Policy and Planning (OMPP) recently announced to the IHCA that it plans to transition to the RUGs IV 66 grouper model for the July 1, 2016 rate effective date. In addition, OMPP indicated that it would also institute a policy that would re-RUG patients at the end of therapy by dropping the therapy weights according to the end date recorded on the MDS and re-grouping the patient into the appropriate clinical category based on the submitted MDS. OMPP estimates that the transition to RUGs IV 66 grouper will result in an reduction of reimbursement of $13.2 M and that a re-RUG’ing at end of therapy will increase reimbursement by $15.6M, for a net increase to statewide reimbursement of $2.4 M. The State is not proposing any reductions to offset the $2.4M increase in overall reimbursement. OMPP distributed a document concerning the proposal, including the RUGs IV 48 grouper model that they have rejected. OMPP also distributed a fiscal impact model that can be accessed here.
IHCA has been advocating for the RUGs IV 48 grouper model as it has a less severe impact on members and is more appropriate for our reimbursement system that is case mix adjusted. As with any reimbursement change there are winners and losers. The primary reason for OMPP’s decision on the 66 grouper was, essentially, care practices have changed since the 34 grouper was created resulting in current over-reimbursement to nursing facilities for patients that don’t require the same level of nursing care, but because the grouper bands are so wide under the current 34 grouper a higher CMI was assigned creating higher reimbursement. OMPP indicated this issue with wide grouper bands resulting in excess reimbursement is also present in the RUGs IV 48 grouper.
IHCA is considering all options to attempt achieving the RUGs IV 48 grouper model. While we believe the 66 grouper decision is likely final, IHCA is engaged in ongoing discussions with the OMPP and the Administration about this issue. We will keep IHCA members informed on the final outcome as soon as possible.
IHCA has been advocating for the RUGs IV 48 grouper model as it has a less severe impact on members and is more appropriate for our reimbursement system that is case mix adjusted. As with any reimbursement change there are winners and losers. The primary reason for OMPP’s decision on the 66 grouper was, essentially, care practices have changed since the 34 grouper was created resulting in current over-reimbursement to nursing facilities for patients that don’t require the same level of nursing care, but because the grouper bands are so wide under the current 34 grouper a higher CMI was assigned creating higher reimbursement. OMPP indicated this issue with wide grouper bands resulting in excess reimbursement is also present in the RUGs IV 48 grouper.
IHCA is considering all options to attempt achieving the RUGs IV 48 grouper model. While we believe the 66 grouper decision is likely final, IHCA is engaged in ongoing discussions with the OMPP and the Administration about this issue. We will keep IHCA members informed on the final outcome as soon as possible.
Tuesday, January 6, 2015
CMS Proposes Rule Concerning Rights of Same-Sex Couples
On Friday, Dec. 12, 2014, CMS issued a proposed rule entitled: Medicare and Medicaid Program; Revisions to Certain Patient’s Rights Conditions of Participation and Conditions for Coverage. The provisions apply to nursing facilities, as well as hospitals, hospices, community mental health centers and ambulatory surgical centers. The changes are consistent with the Supreme Court decision in United States v. Windsor, 570 U.S.12, 133 S.Ct. 2675 (2013), which found the Defense of Marriage Act unconstitutional. The proposed changes impact portions of Resident Rights at §483.10 and Preadmission Screening and resident Review (PASSR) Evaluation Criteria at §483.128. Essentially, the same-sex spouse of a resident must be afforded treatment equal to that afforded to an opposite-sex spouse if the marriage was valid in the jurisdiction in which it took place. Similarly, in the PASSR regulations, same-sex spouses are recognized and treated as an opposite-sex spouse if the marriage was valid in the jurisdiction in which it took place, relative to participation in the PASSR review.
AHCA will submit comments to CMS on behalf of its members. If you have comments that you would like to have considered for inclusion in AHCA’s submission, please email to Zach Cattell at zcattell@ihca.org no later than January 25th. Lyn Bentley at the AHCA is heading up AHCA’s effort on this proposed rule.
AHCA will submit comments to CMS on behalf of its members. If you have comments that you would like to have considered for inclusion in AHCA’s submission, please email to Zach Cattell at zcattell@ihca.org no later than January 25th. Lyn Bentley at the AHCA is heading up AHCA’s effort on this proposed rule.
CMS Issues S&C Memo Concerning Civil Money Penalties
On March 22, 2013, CMS issued guidance to CMS regional offices directing use by regional offices of the CMP Analytic Tool as a guide to choose the type and amount of CMPs when a CMP was determined appropriate by the regional office. The newly issued S&C memorandum, released on December 19, 2014, indicates that the CMP Analytic Tool is still to be used when establishing a CMP, but regional offices are no longer required to submit CMP Analytic Tool cases to CMS Central Office. The S&C Memorandum contains the user guide for the CMP Analytic Tool, which is actually a computer software program internal to CMS. The user guide describes how the tool is used. CMS directs regional offices to use the toll in the calculation of each new or changed CMP imposed within a noncompliance cycle (each of those terms are defined in the S&C). AHCA has been following the development of the CMP Analytic Tool very closely and is preparing analysis of this S&C memorandum. IHCA will make that analysis available to members as soon as it is finished.
Residential Care Facility Citation Update
In November 2014 the ISDH issued 27 Deficiency tags and 2 Offense tags to Residential Care Facilities. Citations concerning food preparation and service areas (Tag 273, cited 4 times) and maintenance of the building and grounds (Tag 144 cited 3 times) were the top citations in October. Tag 241, which is often cited by the ISDH for failure to administer medications by licensed nursing staff or by a QMA, was only cited once in October. Usually this tag is cited 3 to 5 times in a given month. While only cited once or twice in October, respectively, Tag 117, Tag 214 and 217 , and Tag 414, have been consistently cited by ISDH all year. Tag 117 concerns sufficient staffing and staffing qualifications to meet resident needs, Tags 214 and 217 are related and deal with evaluation of residents at admission and on a change of condition, and the documentation by qualified staff to complete an evaluation and review and revised the plan of services. Tag 414 deals with hand washing by staff between each direct resident contact. Facilities should focus on these tags, as well as Tags 273 and 241, mention above for quality improvement activities.
Click here to review a summary of November’s Residential Care Facility Deficiency and Offense citations.
ISDH IJ/SSQC Update
There were two events in November 2014 that led to two IJ citations, both of which were SSQC. The first issue stemmed from the admissions nurse failing to record code status of a resident upon admission, which led to CPR not being initiated for that resident about 14 hours after being admitted. This resulted in death and a F309 citation. The resident had been admitted from the hospital for rehab due to a hip fracture. The hospital records indicated the resident did not have advance directives paperwork, but was noted as full code in the hospital chart. Upon admission the resident’s code statues was not completed and the resident was sent back to the hospital the same afternoon she was admitted to the facility due to a leaking gastronomy tube. When the resident returned to the facility that evening, the code status was still not completed. Overnight the resident was found without respiration and pulse and the LPN that found the resident did not initiate CPR, even though the facility’s policy is to treat all patients as full code if their code status is unknown to the caregiver. The event was cited as past-noncompliance.
The second event related to the worsening of pressure ulcers, one of which was known to staff and another that was acquired at the facility. IN addition, the facility had failed to ensure skin risk assessments had been completed for 4 of 5 residents reviewed. This resulted citation of F314. The ISDH surveyor noted, for both pressure ulcer issues and documentation issues, that assessment and reassessment of ulcers was not performed consistently and orders for treatment of pressure ulcers were at best not documented and likely not performed as ordered.
Click here to access the November 2567 and for the 2014 IJ/SSQC Summary.
The second event related to the worsening of pressure ulcers, one of which was known to staff and another that was acquired at the facility. IN addition, the facility had failed to ensure skin risk assessments had been completed for 4 of 5 residents reviewed. This resulted citation of F314. The ISDH surveyor noted, for both pressure ulcer issues and documentation issues, that assessment and reassessment of ulcers was not performed consistently and orders for treatment of pressure ulcers were at best not documented and likely not performed as ordered.
Click here to access the November 2567 and for the 2014 IJ/SSQC Summary.
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