CMS SNF Open Door Forum Provides Updates on Timelines for MDS Drafts, Schizophrenia Audits
Late last week, LeadingAge National reported the following regarding the March 2nd Centers for Medicare and Medicaid Services (CMS) Skilled Nursing Facility (SNF) Open Door Forum (ODF) related to Minimum Data Set (MDS) timelines and upcoming changes.
New Timelines for MDS Drafts
On the March 2nd ODF, CMS shared updated timelines related to the latest MDS. The final version of the MDS is expected to be released by April 1st, along with a draft of the Resident Assessment Instrument (RAI) Manual. A draft of the data specifications was released in February, with final data specifications expected by May. CMS will release training videos on the MDS beginning in May, with live virtual workshops planned for late June/early July. The final version of the RAI Manual will be released in August. CMS intends to release a draft item set in late April/early May for the Optional State Assessment (OSA), the assessment that states will use to gather needed assessment data for calculating Resource Utilization Group (RUG) payment amounts for Medicaid beneficiaries as they work toward transitioning to the Patient-Driven Payment Model (PDPM) by October 2025. Quality measures (QMs) that utilize Section G in calculations will be transitioned to Section GG later this year, with more information to come.
MDS Transition to iQIES
CMS will transition the MDS to the Internet Quality Improvement and Evaluation System (iQIES) on April 17th. To prepare for this transition, MDS submissions through the current QIES will be cut off on April 13th at 8 p.m. ET. There will be no way to submit MDS data during the blackout period from 8 p.m. ET on April 13th to 8 a.m. ET on April 17th. Providers are still expected to meet all timeline requirements during the blackout period, so will need to plan accordingly. Provider Security Officials (PSOs) and registered users will need to be approved prior to April 17th to avoid delays in MDS submission through iQIES. CMS clarified on the ODF that while every nursing home must have a PSO, only those individuals who directly access iQIES will need Health Care Quality Information Systems (HCQIS) Access Roles and Profile (HARP) registration and iQIES user status. CMS noted that the blackout will not affect the Payroll-Based Journal (PBJ) or ePlan of Care (ePOC). Providers will still have access to PBJ and ePOC through QIES during and after the April 13th blackout. PBJ and ePOC will be transitioned to iQIES at a later date to be determined.
Schizophrenia Audits
Earlier this year, CMS conducted pilot audits to test the effectiveness of the MDS audit process. During these pilot audits, they found several issues related to the inaccurate MDS coding of residents with a diagnosis of schizophrenia. For example, there was an absence of comprehensive psychiatric evaluations and behavior documentation. Also, many residents had only sporadic behaviors noted in their medical records, and these behaviors were related to dementia, rather than schizophrenia. Moving forward, CMS will conduct these audits and, based upon the results, adjust the QM star ratings for facilities whose audits reveal inaccurate MDS coding. This action supports CMS’s goal to reduce the use of unnecessary antipsychotics and improve the accuracy of the QM and the Five-Star Rating System. It is also consistent with the White House’s Fact Sheet listing efforts to improve safety and quality of care in the nation’s nursing homes. Specifically, the Fact Sheet states, “CMS will launch a new effort to identify problematic diagnoses and refocus efforts to continue to bring down the inappropriate use of antipsychotic medications.” Facilities selected for an audit will receive a letter explaining the purpose of the audit, the process that will be utilized, and instructions for providing supporting documentation. During the audit process, facilities will have the opportunity to ask questions and seek any clarification needed. Additionally, at the conclusion of the audit, the facility will have the opportunity to discuss the audit results with CMS.
Facilities that have coding inaccuracies identified through the schizophrenia MDS audit will have their QM ratings adjusted as follows:
- The Overall QM and long-stay QM ratings will be downgraded to one star for six months (this drops the facility’s overall star rating by one star).
- The short-stay QM rating will be suppressed for six months.
- The long-stay antipsychotic QM will be suppressed for 12 months.
Also, CMS plans to offer facilities the opportunity to forgo the audit by admitting they have errors and committing to correcting the issue. This will reduce the burden of conducting audits for CMS and nursing homes and allow CMS to audit more facilities. To incentivize this admission and to promote improvement, for facilities that admit miscoding after being notified by CMS that the facility will be audited, but prior to the start of the audit, CMS will consider a lesser action related to their star ratings than those listed above, such as suppression of the QM ratings (rather than downgrade).
The link to the QSO on the audits can be found here. Facilities are urged to read the QSO in its entirety and share with their MDS coordinators.
Contact: Amy Nelson, anelson@leadingageny.org, 518-867-8383 ext. 146