On Monday, CMS issued a memo titled, “Quality Measure Rating Threshold Changes with the April 2022 Refresh”. This memo indicated that CMS plans to change the QM rating thresholds every six months. This will begin in April of 2022. This probably seems like short notice for a change of this magnitude.
Back in 2019, CMS issued memo QSO-19-08-NH. It described the process which will be used to update the quality measure point thresholds. The threshold changes reflect average rate improvements in the QM rating scores and are used in the calculation of 5-star ratings. These biannual changes are to incentivize continuous quality improvement.
This process was to go into effect in 2019. However, the COVID PHE put a pause on those plans. CMS believes now is the right time to move forward.
How will this work?
Every six months, QM thresholds will increase by 50% of the average rate of improvement in QM scores. For example, if there is an average rate of improvement of 2%, the QM threshold would increase by 1%.
The purpose of this is to incentivize continuous quality improvement. Additionally, it will reduce the need to have larger adjustments to the thresholds in the future.
In the memo CMS noted that threshold and methodology changes will cause many nursing homes to decline in QM rating. Consequently, this could further lead to a reduction in overall rating.
Although a decline in a Five Star rating, absent any new inspection information, does not necessarily represent a decline in quality. In other words, if a rating changes, it may not have been due to any change in operations or level of care. In these cases, the change in rating would represent a change in the methodology for calculating certain measures. Conversely they also indicated that some nursing homes will see an increase in rating, rather than a decrease.
How to prepare?
It is important be aware that these changes will take effect with the April 2022 Care Compare refresh. That will happen about a month from now. (3/22/2022) CMS didn’t give us much heads up that these changes were coming. Therefore, it is critical that you educate yourself on your April 5-star rating. Take some time to understand fully any changes that may occur.
Which Quality Measures Affect 5-Star?
- MDS Based Long Stay: (As a percentage, long-stay residents…)
- Whose need for help with daily activities has increased
- Whose ability to move independently worsened
- At high-risk for pressure ulcers
- Who have or had a catheter inserted and left in their bladder
- With a urinary tract infection
- Experiencing one or more falls with major injury
- Who got an antipsychotic medication
- Claims Based Long Stay:
- Number of hospitalizations per 1,000 long-stay resident days
- Number of outpatient emergency department (ED) visits per 1,000 long-stay resident days
- MDS Based Short Stay: (As a percentage, short-stay residents…)
- Who improved in their ability to move around on their own
- With pressure ulcers pressure injuries that are new or worsened
- Who got antipsychotic medication for the first time
- Claims Based Short Stay:
- Percentage of short-stay residents who were re-hospitalized after a nursing home admission
- Percentage of short-stay residents who have had an outpatient emergency department (ED) visit
- Rate of successful return to home and community from a SNF
- Check your CASPER folders in April for important 5-star related reports. Your facility 5-star preview reports are issued via CASPER around the 20th of each month. This will give you your 5-star breakdown before the update happens on Care Compare.
- Next, review the QM cut point thresholds when the update is released. CMS plans to release a revised 5-star user’s guide along with the April 2022 Care Compare refresh. Check the CMS Five-Star Quality Rating System website frequently.
Lastly, we will provide an analysis of the changes when they occur. Stay tuned for more on this unfolding topic in an upcoming Regulatory Reminder.