ISDH Proposing Changes to the Report Card Score

IHCA was recently informed that the ISDH wants to change the way Report Card Scores (RCS) are calculated.  In short, the ISDH use a higher score to indicate better regulatory compliance (today, the lower score equals better compliance).  The scoring would start all facilities would with 300 points then points would be deducted based on each tag received during any survey.  The ISDH wants to score to reflect all tags and from all surveys over the past 30 month period, excluding life safety code tags and substantial compliance tags (A, B and C).  No extra points would be deducted for IJs or SSQC tags. Click here for a description from the ISDH.

IHCA has obtained a facility by facility breakdown of the current scores and the proposed scores (click here to access that report).  This breakdown is very preliminary and IHCA is examining the data sources for this report.  We are concerned with a few items within this concept, and have found a few examples that validate those concerns.  First, in some cases tags get cited twice during a complaint investigation that is done during an annual survey.  Said another way, two 2567s are generated, one for the complaint and one for the annual survey, and the same tags cited in the complaint get cited in the annual.  This improperly penalizes the facility, especially if all tags will be used in a new report card score methodology.  Next, we are concerned with the point allocation proposed by the ISDH, D-E-F citations get 3 points, then the scale jumps to 20 points for any G-H-I citations.  We think this is confusion and we want the ISDH to look at both scope and severity when allocating points, like in the current system.  There are a couple of other issues and questions within ISDH’s process that we are examining, such as frequency of scores being updated and how to account for geographic variation in surveys.  That said, we are encouraged by the new system’s design that only looks back at the most current 30 months of surveys, thereby allowing facilities to improve in their scores without having to wait for the next annual survey to be completed, as in the current system.

As you may be aware, the ISDH RCS is used by Indiana Medicaid to determine a large portion of the Value Based Purchasing Add-on within the Medicaid rate.  There have not been any discussions as of yet on how this newly proposed RCS would or would not be used in the add-on.  IHCA is meeting with Indiana Medicaid representatives on an ongoing basis regarding the Medicaid rate setting methodology and will be discussing this issue very soon with Indiana Medicaid.  In addition, IHCA’s Payment/Reimbursement Committee will discuss this at its next meeting on June 17th.