In a recent blog post, we alerted you that CMS published an update for FY 2017 on the Special Focus Facility Program. Being selected as a Special Focus Facility (SFF) is problematic for several reasons for a nursing home, included being surveyed at least once every six months versus the traditional recertification survey cycle. Nursing Home Compare also highlights this status on its website with a warning sign, alerting potential clients that a facility is a consistent poor performer. Then, CMS can utilize its “progressive enforcement” options until the facility either improves its quality to graduate from the program or is terminated from Medicare and Medicaid. In recent years, facilities on the list have been listed for 36+ months in some cases, and the new S&C memo outlines how CMS will be moving facilities more quickly through the program – so for SFFs, it appears there may be a shape up or ship out mentality moving forward.
Selection of SFF Candidates
CMS has aligned the methodology for selecting a candidate pool for each state with the methodology for the health inspection domain of the Five-Star Quality Rating System. The health inspection domain is calculated based on:
- The number, as well as Scope/Severity of deficiencies identified on annual inspection surveys for the 3 most recent standard surveys
- The number of substantiated findings and their Scope/Severity for the most recent 36 months of complaint investigations
- The number of revisits required to ensure identified deficiencies have been corrected
CMS provides a list of potential candidates to the State Agencies (SAs) to select SFFs from. The SA makes recommendations based on the candidate list, and then the CMS RO provides final approval of SFF candidates. For each available SFF slot within a state, five potential candidates are provided (up to 30 per state). The number of slots and candidates was not revised in this S&C letter, and the number remains the same as it was set out in early May 2014. You can view the number of candidate slots and the candidate pool by state here. When a facility graduates from the SFF list or is terminated from Medicare/Medicaid, the SA is required to select a replacement facility for the SFF program within 21 calendar days from the date the slot opens up. You can view the March 16, 2017 SFF List here.
What happens if your facility is selected for the Special Focus Facility program? Check the CMSCG Blog shortly for information on what happens next. Has your facility already received notice that it is a candidate for the CMS SFF Program? We can help. Fill out the contact form below and someone will get back to you with information on how CMS Compliance Group’s interdisciplinary compliance consultants can help your nursing home improve its survey outcomes and strengthen its systems to help you show improvement and graduate from the SFF list.