I love a good summer thunder storm. For me it’s relaxing and clears the air. Outside there is a sense of newness after it passes and everything seems fresher.
CMS has created a storm of their own with a pair of recently released QSO memos, QSO-25-20-NH and QSO-25-19-All.
With QSO-25-20-NH, CMS has changed the criteria for the 5-star rating with the click of a pen. There are two important revisions to which we all need to pay attention.
The What
First, starting with the July quarterly update to care compare, CMS has changed the criteria for the health inspection portion of the 5-star rating calculation, the foundation of your star rating. Specifically, CMS has decided to drop Third Cycle Standard Surveys from the Nursing Home Care Compare Health Inspection Rating.
The Why
The rationale? CMS believes that due to the backlog in surveys, that third-cycle standard health inspections may not accurately reflect the current performance of nursing homes. CMS has indicate that this change will have minimal impact on overall ratings, with most facilities maintaining their current health inspection ratings.
However, they acknowledge that there will be meaningful changes for roughly 20% of nursing homes. That’s 3000 nursing homes if your doing the math. That’s not a small number. Some of those could end up with a better health inspection rating, others will not be so fortunate. Here’s why.
Besides removing the third survey cycle, they have also significantly changed the weighting of the 2 remaining survey cycles that will be counted. The table below indicates that the first, the most recent survey along with complaint and infection control surveys in the last 12 months, will be weighted at 75% and the second most recent survey along with all other complaint and infection control surveys in the last three years, will be weighted at 25%.
With little advance warning, the lightening has struck and facilities will feel the effects with the July update to Care compare. Here is what CMS indicated in QSO-25-20-NH would be the immediate effects for facilities that will experience changes to their star ratings.
The How
“For facilities that had serious quality issues three surveys ago, but have taken strong steps to improve their quality, this change removes the negative impacts from their old performance and gives them credit for their efforts. Conversely, facilities that had high performance three surveys ago, but had significant deterioration of quality, this change will no longer allow providers to continue to benefit from old performance that doesn’t reflect current conditions. Ultimately, this gives consumers a better picture of a nursing home’s current quality level.
Consider also the following situation. A facility has a stellar performance on the most recent cycle 1 surveys and very poor performance in cycle 2 surveys. Even though cycle 2 may only be weighted at 25%, it can still have a major impact of the total points associated with the star rating. Now, while facilities may not experience the negative or positive effects of the third cycle under this revised calculation, cycle 2 can still have a significant impact on the total score and star rating.
Here’s an example, a facility that has improved with 10 total points in cycle 1 but had 150 points in cycle 2 would now have a total weighted score of 45 points. In at least one state that equates to a 1 star health inspection rating. In several others that keep you at the 2-stars.
If a consumer did not dig into the data in that scenario, they would not realize the gains made in the most recent survey and we’re back to misconceptions about current performance.
What now?
Time is of the essence here. It may be a good idea to take a look at your current survey scores and make some projections about what you might see when Care Compare updates in July.
Here’s the calculation ((Cycle 1 survey scores + scores for complaint and infection control surveys in the last 12 months)* .75)) + ((Cycle 2 survey scores + the remaining complaint and infection control survey points in the last 3 years)*.25)).
That total score would then be compared against the health inspection cut point tables in your state to approximate your July health inspection star rating.
Your staffing and quality measure stars will continue to impact your overall star rating just like they do now. Stay tuned for Part 2 of this blog series to understand more about changes that CMS will be making to one of the quality measures that will affect your star ratings in October. It’s a doozy.
