It seems the overarching theme of the whole CMS Nursing Home Action plan should have been quality improvement, but CMS waited until Strategy 4 to discuss the topic. We have written about Strategies 1-3 on the CMSCG Blog in the past few days, so be sure to catch up if you haven’t, otherwise feel free to proceed on to Strategy 4, “Promote Quality Improvement.” Let’s look at how CMS is pushing continuous, systematic quality improvement in nursing homes.
- Updates to the MDS – The MDS 3.0 is about so much more than just reimbursement, and we are glad to see that CMS reminded providers that the primary purpose of the MDS is its use as an assessment tool to identify resident care problems so they can be addressed in the individualized care plan. CMS continues to revise the MDS 3.0 annually, and this year’s October update will include something new – standardized items that have been authorized by the IMPACT Act.
- MDS 3.0 Focused Survey – The pilot results of the MDS Focused Survey were important because surveyors were able to identify and cite deficiencies on all but one survey from the pilot group. Those results showed CMS that MDS accuracy could be a problem for many nursing homes, and the survey type was rolled out nationwide in 2015.
- Quality Assurance and Performance Improvement (QAPI . . . underway?) – QAPI materials have been available to nursing homes for several years now, and we all know that a QAPI program is coming for this provider type . . . at some point. The proposed rule we mentioned in a prior blog post includes the proposed requirements for QAPI, but until that rule is finalized, we won’t know 100% what it looks like.
- Preventing Adverse Events in Nursing Homes – The medicated-related adverse event tool and corresponding pilot Focused Survey on Medication Safety Systems help surveyors to investigate and understand potential adverse events related to medications in nursing homes. Further information about this pilot survey and a potential expansion is not provided in this document. The April 2016 OIG Compendium of Unimplemented Recommendations notes that CMS is supposed to develop lists of two categories of potential adverse events -patient care events and infection events. These lists have not yet been completed/released.
- Nice work by the National Partnership! – The National Partnership to Improve Dementia Care update was published in a June 3 S&C letter. The Nursing Home Action Plan notes that while there have been good results in reducing the use of antipsychotics in nursing homes, that surveyors must look at other categories of medications under F-329 for unnecessary use.
- More Quality Measures Coming – CMS continues to develop QMs, including the use of claims data to look at quality.