SNF QRP Part 1: What is the Quality Reporting Program?

The Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 required CMS to implement quality measures from five different quality domains. These quality measures were to be derived from the use of standardized data elements included with the assessment instruments currently completed by the various post-acute providers (SNFs, LTCH, IRF and HHA). The five quality domain areas are:

  • Functional status, cognitive function, and changes in function and cognitive function.
  • Skin integrity and changes in skin integrity.
  • Medication reconciliation.
  • Incidence of major falls.
  • Communication and transfer of health care information for successful transitions between health care providers or to home.

In addition, the IMPACT Act also requires the development and reporting of measures pertaining to resource use, hospital readmissions, and discharges to the community.

The reporting of three of these domain measures will begin October 1, 2017 (FY2018) via the CMS Nursing Home Compare (NHC) website and will only utilize data for Traditional Medicare Part A (Fee-For-Service) residents only.

You can view the entire text of the IMPACT ACT here.

What are the Quality Measures to be used in the QRP?

To meet the requirements of the IMPACT Act, CMS finalized three of the quality measures that will satisfy three of the 5 required domains (1, 2 and 4 listed above):

  • Percent of Residents with Pressure Ulcers that are New or Worsened (Domain: Skin integrity or changes in skin integrity).
  • Percent of Residents Experiencing One or More Falls with Major Injury (Domain: Incidence of major falls).
  • Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function. (Domain: Function and Cognitive function and changes).

Although the third QM listed addresses patients in a Long-Term Care Hospital, this measure will also be adopted and separately calculated for SNF residents.

Each of these QMs will be derived from submitted MDS data only. In order to accurately calculate these measures for Medicare Part A residents, CMS will be implementing changes to the current MDS 3.0 on 10/1/2016. Primarily SNF providers will see two significant changes:

  • Implementation of a new End of Medicare Discharge assessment; and
  • Addition of a new Section GG related to a resident’s functional status and goals.

Each of these two new MDS 3.0 developments will be discussed further in future segments of this QRP learning series.

Since CMS will be relying on self-reported MDS data to accurately calculate each of these QMs, it will be important for SNFs to ensure that all data necessary to calculate these measures are submitted to the QIES ASAP system. CMS has finalized a provision of the QRP that will financially penalize SNFs who fail to submit the necessary MDS data, for each of the QRP QMs, on at least 80% of the MDS assessments submitted. This financial penalty will consist of a 2% reduction in the FY2018 market basket for SNF PPS payments.

Implementation Timeline

Although the actual reporting of quality measure data will not begin until October 1, 2017 CMS will begin data collection 1 year earlier on October 1, 2016. For the first year of the QRP, CMS will collect and utilize data from only one quarter, 10/1/2016 through 12/31/16. CMS will transition to yearly calculations using the following timeline:

Data Collection Period Data Reporting
10/1/2016 – 12/31/2016 (3 months) October 1, 2017
01/1/2017 – 9/30/2017 (9 months) October 1, 2018
10/1/2017 – 9/30/2018 (12 months) October 1, 2019
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Part 2: A closer look at the Quality Measures: Incidence of Major Falls

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