Everyone likes to be validated. To be seen and heard isn’t enough. Social media only exacerbates the craving. How many likes can I get for my posts and comments? It’s a never ending quest.
Validation Mania!
When it comes to the MDS validation has, until now, been relegated to the Medical Review world where the HIPPS code is scrutinized regularly by a variety of review agencies like the MACs and Meyers and Stauffer.
In the last two rule making cycles, CMS has introduced us to a new MDS validation process that is slated to begin this fall.
According to a Q&A document recently posted to the Skilled Nursing Facility (SNF) Validation Program website, this new process is an audit-based program established to assess the accuracy of Minimum Data Set (MDS)-based quality measures used in the SNF Value Based Purchasing (VBP) and Quality Reporting Program (QRP).
Is it me?
SNFs will be selected randomly from all SNFs eligible for the validation program. SNFs can only be selected once within a fiscal year. SNFs that submitted at least one MDS assessment record in the previous calendar year and have submitted at least one MDS assessment record in the current fiscal year are eligible for selection.
This means you! So get ready. SNFs selected for audit will be notified through their Internet Quality Improvement and Evaluation System (iQIES) MDS 3.0 Provider Preview Reports folder.
The audit notification will contain instructions for documentation submission, the list of sampled residents for which medical charts are being requested and contact information for the contractor conducting the audit.
That’s a clue to be checking your IQIES folders regularly starting this fall.
It’s a team challenge
In order for facilities to respond, SNFs must designate and submit points of contact (POCs) to receive audit-related email notifications, including file uploads, documentation submissions, and any issues with medical chart records.
To do this, a POC link will be provided in the SNF audit notification. Facility staff can click on the original POC link that was provided and enter revised POC information. This will automatically update the SNF POC information.
Time is of the essence
When notified, SNFs will be required to submit requested medical chart documentation to support validation of 10 MDS assessment records. SNFs have 45 calendar days from the date of audit notification upload to submit medical chart documentation to remain in compliance with validation program requirements.
Any selected SNF that fails to submit requested medical chart documentation within 45 calendar days of the audit notification will be considered noncompliant. Audit notifications will provide detailed data requests for resident medical charts associated with the sampled MDS assessment record.
SNFs that are selected for validation will submit requested medical chart documentation in a PDF format through a secured portal. The URL to a SNF’s secured portal is included in the audit notification letter along with detailed instructions on how to upload files.
Am I validated?
At the conclusion of the audit, SNFs will receive a Summary Audit Scoring Report via iQIES. The report will contain the SNF’s audit results for each measure and MDS item, including detailed results from each sampled assessment and medical chart audited. The reports are for informational purposes only; SNFs will not be penalized for their audit results.
However, for the FY2025 performance year/FY2027 program year, noncompliance (failure to respond to the validation request within 45 days) may result in a 2% reduction of a SNF’s Annual Payment Update for the FY2027 SNF QRP program year.
According to the FY 2025 final rule, the 2% reduction is not cumulative. Non-compliance just means that there will now more ways to lose 2%.
Selected SNFs will also receive a Summary Audit Scoring Report that will include a notification that they were noncompliant with the Validation Program. SNFs will also receive a non-compliance notification letter from their Medicare Administrative Contractor (MAC).
I heartily Disagree!
SNFs may file for reconsideration if they believe the finding of noncompliance is in error.
A SNF that disagrees with the compliance determination and the impending payment reduction decision may submit a request for reconsideration to CMS within thirty (30) days from the date at the top of the noncompliance notification letter. CMS will not accept any requests submitted after the 30-day deadline.
Not the validation I was looking for
While we may not like it, we need to prepare. The SNF VBP and QRP programs carry financial incentives related to reporting standards and performance so CMS is serious about making sure the MDS supports our QMs.
CMS has indicated that these audits will cover both the SNF VBP and QRP measures at the same time. The good news is that there will not be separate audits for both programs.
That said, the following MDS based quality measures are potentially in play
- Falls with major injury (both Long and Short stay versions)
- Discharge mobility and self-care score
- Drug Regimen Review with follow up
- Transfer of healthcare information to provider and patient
- Discharge Function Score
- Patient Covid-19 vaccination is up to date.
Stay focused. If you have only checked IQIES infrequently, make a plan to do it more often. You don’t want to miss these notifications.
MDS accuracy is paramount. Be sure your POCs are up to date. Respond when notified.
The validation you never wanted is on it’s way. What it reflects is up to you and your team. Get out there and shine!
