We knew it was coming and it is here. CMS released the 5-Star preview reports yesterday and they can be downloaded from your CASPER folder in QIES. This data is what will be publicly reported on or around October 28th on the Nursing Home Compare and Care Compare websites. There are a few things to which we need to pay attention which we talked about in the Broad River Reflections webinar last Thursday and spent some time with in the follow up Q&A blog.
PBJ
First, remember that the October refresh to NHC will include a 5-Star rating that will include Q2 2020 PBJ data. Providers were required to resume reporting PBJ data for Q2, after a brief pause due to the COVID PHE, by Aug. 14th. Quarterly PBJ data will now be included with the data that appears on NHC. CMS has indicated that while health inspection data and quality measure are being held constant, a facility’s overall star rating could be affected positively or negatively on a quarterly basis relative to submitted staffing data. This is a current understanding of the dynamics that will drive 5-star ratings over the next few years. See clarification note below.
Quality Measures
Next, the quality measures that are posted on the preview reports are the quality measures that will be publicly reported. Note that this information is reflective of QM data that is current as of December 31st 2019 except for the Return to Community QRP measure data which spans 10/1/2017 through 9/30/2019. Due to the reporting waiver that was in place for the first 2 quarters of 2020, the next time QM data can be refreshed will be January 2022, with a full update in April 2222. That said, QM data that will post to NHC in October will remain constant until the next refresh in 2222. One caveat is that underlying QM data that catches up to Dec. 31, 2019 could have an impact on the QM and overall star ratings, like when a MDS assessment that was completed in 2019 is modified after Dec. 31 2019. One other very important change to the quality measure domain with the October refresh, that is also contained in the preview report, is the replacement of the Pressure Ulcer New or Worsening QRP measure with the new QRP measure Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury. This measure calculates new or worsened pressure ulcers differently than the previous measure so your numbers may look different with a possible commensurate effect on your QM and overall star rating. Note that this new measure is now being reported on your CASPER reports as well.
Health Inspections
Finally, the health inspection rating will also remain constant for the time being. Because of the way that CMS has shifted its attention to COVID-19 and infection control issues in nursing homes relative to its survey activity. “…there has been a great shift in the number of nursing homes inspected, and how the inspections are being conducted. Without action, this would have disrupted the inspection domain of the Five-Star Quality Rating System because many nursing homes that would normally be inspected, will not, thereby over-weighting and impacting the ratings of those facilities that are inspected. This could then potentially mislead consumers. Since the NHC refresh in April 2020 and until further notice, the health inspection domain of the rating system is being held constant to include only data from surveys that occurred on or before March 3, 2020. Results of health inspections conducted after that date will be posted publicly, but not be used to calculate a nursing home’s health inspection star ratings.” CMS has indicated that they will restart nursing home inspections as soon as possible and will notify the provider community in advance of any updates to Nursing Home Compare and the star ratings. Similar to the QM data, any new surveys or changes to survey results that were conducted on or before March 3, 2020 that enter the national database will be included in the health inspection rating calculation, potentially causing a change in the health inspection and overall rating for an individual facility.
Clarification to reflections Q&A #4 – This is a clarification to our recent blog posting where we indicated, based on what was known at the time, that we believed the overall star rating would also remain constant after any updates to QM and Health Inspection data catching up to their respective cut off points. However, now that the 5-Star preview reports are out, CMS has indicated that since the PBJ staffing data reporting has restarted and that new staffing data will be reported quarterly, even while QM and health inspection data is held constant on NHC, changes to the staffing star based on quarterly reporting could potentially impact the staffing and overall star rating. It will be important for facilities to continue to pay attention to changes to their star rating monthly and quarterly to be sure they are aware of any changes that may occur based on the possibilities noted above. Facilities should also pay close attention to their CASPER reports so that they can continue PI/QA/QAPI activity relative to this, more current, QM data.
Don’t forget to download your 5-Star preview reports. We would love to answer any QM or 5-Star questions you may have. Give us a shout at our Ask Our Experts link today.
