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DOH Posts Nursing Home Quality Initiative Score Sheets for Review

Providers have until Dec. 8th to review their 2022 Nursing Home Quality Initiative (NHQI) results and submit questions to the Department of Health (DOH). The preview score sheets are posted on the Health Commerce System’s (HCS) Healthcare Financial Data Gateway in the same place as facility Medicaid Rate Sheets. Accompanying the posting is the Dear Administrator Letter (DAL) that includes a description of the 2022 NHQI methodology as well as a guide for interpreting the score sheet (also available here). Questions should be submitted to nhqp@health.ny.gov. After Dec. 8th, DOH will finalize the quality scores, assign overall quintiles, and add the information to the compilation of NHQI data from prior years that is posted on HealthData NY. The 2022 results will then be used as the basis for adjusting Medicaid rates, a process that shifts $50 million in existing funding from those homes with poor NHQI scores to those whose overall score puts them in one of the top three quintiles.

In advance of posting the review score sheets, the Office of Quality and Patient Safety convened the NHQI Workgroup to review the results of Payment Year 2022 NHQI, which is based primarily on 2021 measures, and to provide an overview of the proposed 2023 NHQI measure set, which will be based on 2022 measures. Key information is outlined below.

2022 Results

After being suppressed for 2021 due to reliability concerns precipitated by the pandemic, five long-standing measures were reinstated in 2022. While this makes the overall structure of the 2022 measure set similar to prior years, the fact that these measures were out of commission in 2021 meant that there were fewer opportunities for facilities to earn improvement points for 2022. A point is only awarded when a facility scores in a higher quintile than in the previous year on the same measure. However, even with this restriction, 78 percent of facilities received at least one improvement point.

The 2022 NHQI also debuted two new measures: nursing staff turnover and the percentage of current residents up to date with COVID-19 vaccines. Both measures are used in the federal Five-Star system and are calculated in the same way, although points for the turnover measure are assigned based on a regional, rather than statewide, comparison. This is a similar approach that is used for the health inspection measure in recognition of significant regional variation, although the inspection measure uses four regions, while the turnover measure relies on two (Metropolitan Area Regional Office (MARO) and no-MARO). For the COVID-19 immunization measure, National Healthcare Safety Network (NHSN) reporting for the week ending Dec. 18, 2022 was used, defaulting to the prior week if data were missing. For 2022, the compliance measure that awarded points for timely filing of the Medicaid cost report was discontinued, meaning that there are no longer any NHQI measures that depend on cost report filing or data.

The timeframe of the data used in the 2022 NHQI is as follows:

  • Minimum Data Set (MDS) measures are based on Calendar Year (CY) 2021
  • Long-stay Resident Flu Vaccination Rates based on October 2020 – June 2021 MDS data
  • PBJ Staffing Data based on four quarters of CY 2021
  • Employee Flu Vaccination Rates based on 2021-22 Flu Season (HERDS Reporting)
  • Regionally-adjusted Health Inspections as of April 2022
  • Total Nursing Staff Turnover for CY 2021
  • Resident COVID Immunization Rate from NHSN Reporting for Week ending Dec. 18, 2022
  • J/K/L Deficiencies awarded between July 1, 2021 and June 30, 2022

When it comes to comparing individual measures that were present in both the 2022 and 2021 NHQI, the percentage of long-stay residents receiving the pneumococcal vaccine declined year over year, while the proportion of long-stay residents receiving the influenza vaccine improved. Not surprisingly, staffing and contract staff utilization measures showed a negative trend, while measures of long-stay resident incontinence, activities of daily living (ADL) decline, and prevalence of urinary tract infection (UTI) all showed improvement. The percentage of employees vaccinated for influenza decreased from 68 to 52 percent. The number of homes with a J, K, or L deficiency increased from 13 in 2020 to 32 in 2021.

2023 NHQI Methodology (Proposed)

For the 2023 payment year (2022 measurement year), DOH is proposing minor changes: the discontinuation of one quality component measure, the addition of one measure, and a calculation change for one existing measure.

  1. The measure that would be discontinued because the measure is no longer being maintained by the Pharmacy Quality Alliance Forum:
    • Percent of long-stay residents with dementia who receive an antipsychotic medication.
  2. The measure being considered for addition whose data source and timing would mimic the resident COVID-19 vaccine measure:
    • Percent of current healthcare personnel up to date with COVID-19 vaccines.
  3. The calculation of the current compliance measure “Percent of current residents up to date with COVID-19 vaccines would be calculated based on all residents, not just those with no medical contraindication, based on the data available from the Centers for Medicare and Medicaid Services (CMS).

Any member with questions or who is willing to share reactions or suggestions to the 2023 proposal is asked to contact us. We encourage all members to review their 2022 score sheets prior to the Dec. 8th deadline and to let us know if they identify any concerns.

Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841