In a new “CMS: Beyond the Policy” podcast, CMS Administrator Seema Verma and Dr. Kate Goodrich, CMS Chief Medical Officer discuss the 5-point strategy announced recently that aims to improve oversight in nursing homes. Here are some key takeaways:
- Survey timeframes shifting? President Trump asked Congress to provide CMS with the ability to adjust the frequency of nursing homes surveys. The shift to a risk-based survey model would provide CMS with the ability to focus on its poor performers and potentially conduct more surveys, including investigating every complaint. By contrast, high-performing nursing homes who don’t have complaints against them could potentially be surveyed using a survey window greater than every 12-15 months which would allow CMS to use its surveyors to review low-performing nursing homes.
- Increase in data-driven oversight – CMS has recognized and is taking steps to increase consistency in the survey process as well as State Agency oversight. Administrator Verma discussed inconsistencies in issues identified in nursing homes that may occur in one CMS region but not another. The LTCSP is computer-based and data-driven, providing CMS with analytics to identify patterns of inconsistency to help ensure that nursing homes are “evaluated on kind of a level playing field,” the moderator noted. The data will also be used to analyze what State Agencies are doing with the tool so CMS can work with the SA to address outliers, such as citations in a particular area that “seem out of the norm” from other regions, Verma noted.
- Utilizing the CMS “treasure trove of data” – Dr. Goodrich discussed the amount of data the is being mined to identify patterns and staff members at nursing homes who have a previous history of abuse. This data will be used to update Nursing Home Compare in some manner to show nursing homes with issues related to abuse or neglect.
The focus of this podcast was definitely on the idea that CMS will be utilizing all the data that it is gathering to drive the manner in which it operates and how nursing homes are overseen. We have seen this in the shift to utilizing Payroll-Based (PBJ) data rather than facility-reported data, as well as with the increasing requirements to submit data for initiatives like the SNF Valued-Based Purchasing (SNF VBP) program and the SNF Quality Reporting Program (SNF QRP).
It will be interesting to see if CMS is able to create more consistency in the survey process, since here at CMS Compliance Group, we analyze a lot of data and we consistently identify inconsistencies at a national, regional, state and local level. This lends itself to the idea that surveyors are not reviewing facilities in the same manner and is a reminder to facilities to ensure they have a good handle on what is going on locally when they are in their survey window. The bigger question is if you are a “higher” performer, what is your plan to guarantee consistent high performance so that you do not fall victim to complaint surveys or poor survey results that will definitely color your 5-Star rating?
You can listen to the CMS podcast, “Episode 5: Nursing Home Strategy Part 1 – Strengthening Oversight,” here. To learn more about the 5-point plan, view our April 2019 blog post, “CMS Blog – Ensuring Safety and Quality in America’s Nursing Homes.”