Regulatory Reminders!

It’s a new year and CMS is not wasting any time. Late Friday, 1/7/2022, CMS released memo QSO-22-08-NH.  In this memo CMS has laid out their intentions to begin using PBJ data inform the public related to weekend staffing and staff turnover in 3 distinct ways.

Public Posting on Care Compare

  • CMS will begin posting data on the level of weekend RN and total nurse (e.g., RN, licensed practical nurse (LPN), certified nurse aide (CNA)) staffing for all nursing homes on the Care Compare website in January 2022. This will be reported in terms of the average number of RN and total nurse hours worked per resident per day on weekends.
  • CMS plans to post the following measures of staff turnover in January 2022
    • The percent of RN staff that left the facility over the last year.
    • The percent of total nurse staff that have left the facility over the last year.
    • The number of administrators that have left the facility over the last year.

Update the 5-Star Rating

  • To encourage facilities to increase nurse staffing on weekends, CMS will add the measure of total nurse staffing (e.g., RN, licensed practical nurse (LPN) on weekends to the staffing rating domain of the Nursing Home Five Star Quality Rating System in July 2022.
  • CMS plans include the following measures in the staffing domain of the Nursing Home Five Star Quality Rating System in July 2022:
    • The percent of RN staff that left the facility over the last year.
    • The percent of total nurse staff that have left the facility over the last year.
    • The number of administrators that have left the facility over the last year.

Updating Data.CMS.gov

  • CMS will be posting the employee-level staffing data in January 2022 for stakeholders to conduct their own analysis, i.e. to analyze staff turnover, to help improve nursing home staffing. The employee-level data will be posted in the PBJ section of data.cms.gov on January 26, 2022. Additionally, CMS will add the measures of turnover and weekend staffing to the facility-level files posted on the Provider Data Catalog, in the section for “Nursing homes including rehab services.”

In this memo CMS also reminded  providers of situations when a facility changes its employee identifiers. For example, when facilities change their payroll or time-keeping system, it may be necessary to change its employee identifiers. Employee identifiers are used to calculate each facility’s staff turnover measures by identifying when each employee starts and stops working at a facility. If a facility changes an employee’s identifier, that event is viewed the same as an employee ending their work at a facility. Therefore, it is critical that facilities use the methodology to link old and new employee identifiers together when these identifiers change. If a facility does not do this, it will artificially increase its staff turnover measures, which can be viewed as worse performance. Here are the instructions and links to documents that will help you ensure facilities can properly link employee identifiers to ensure their turnover measures are accurate.

Finally, CMS indicated that the technical specifications for weekend staffing and staff turnover measures will be included in the Five Star Rating System Technical Users’ Guide on January 14, 2022.

Staffing is definitely taking on a greater role in nursing home quality measurement. More to come as we dissect the updated 5-Star user’s  guide late this month.