The Centers for Medicare & Medicaid Services (CMS) has updated its Five-Star Quality Rating System Technical Users’ Guide to explain changes made to the survey star rating methodology. The changes, which we reported on in November of 2017, have remained consistent with the information outlined in the CMS memo “Temporary Enforcement Delays for Certain Phase 2 F-tags and Changes to Nursing Home Compare,” dated November 24, 2017. Here’s a brief overview of what you need to know:
- As a result of the new LTCSP and the new set of Ftags, CMS has decided to not use any deficiencies cited on surveys that occurred on or after November 28, 2017 for calculating the Health Inspection rating for 12 months.
- The Health Inspection rating will be based on the results of a provider’s most recent 2 standard surveys that occurred prior to November 28, 2017 (before the LTCSP was implemented) and any deficiencies from complaint investigations for the same period. Deficiencies are weighted by scope and severity and take into account the number of revisits required to ensure identified deficiencies have been corrected.
- Nursing Home Compare will include information on any standard or complaint surveys that have taken place since November 28, 2017, but they will not be calculated as part of the Health Inspection domain for a period of 12 months beginning February 2018. That means that the Five-Star Quality Rating will not be fully updated until February 2019.
- Facilities that only have one standard health inspection prior to November 28, 2017 will be reported as “Too New to Rate” since they do not have sufficient data to determine a Health Inspection rating. These facilities will have no overall quality rating, and no ratings for staffing or quality measures either.
- Deficiencies cited on Life Safety surveys will still not be included in Five-Star rating calculations.
- Deficiencies that are found on Federal Comparative Surveys are excluded from the Five-Star calculations and are not posted on Nursing Home Compare, but the results of State Agency (SA) determinations made during those surveys are included. Don’t forget that the Federal Oversight Support Survey Process Pilot that began in January will continue until the end of September. Surveyors will be conducting Focused Comparative Surveys during Phase 2 of the pilot (May 1, 2018 – September 30, 2018). A federal surveyor will be conducting an independent investigation of three focus areas – abuse and neglect, admission, transfer and discharge, and dementia care – using the LTCSP investigative protocols and pathways. A Phase 2 survey sample will be comprised of 60% of the State survey sample of residents that triggered for the above-mentioned areas. If any SQC, Harm-level or Immediate Jeopardy citations are identified by the surveyor, a 2567 will be issued.
- Items that could result in changes to the Health Inspection score include:
- Surveys that occurred prior to November 28, 2017 that have not yet been added to the CMS national database could change the score in the month following its entry into that database
- Second/third/fourth revisits associated with surveys occurring prior to November 28, 2017. No points are assigned to first revisits, but points for more than one revisit are assigned in a proportional manner to the Health Inspection score. CMS notes in the document that providers who “fail to demonstrate restored compliance with safety and quality of care requirements during the first revisit have a lower quality of care than other nursing homes. More revisits are associated with more serious quality problems.”
- Resolution of Informal Dispute Resolutions (IDRs) or Independent Informal Dispute Resolutions (IIDRs) that result in changes to scope/severity of deficiencies for surveys that occurred prior to November 28, 2017.
CMS Compliance Group’s compliance and quality improvement consultants are here to help you proactively improve the quality of care and services provided in your facility. View our services for skilled nursing facilities to learn about how we can partner with your organization or contact us to discuss further.
