CMS Announces Updates to NHC Staffing & Quality Measures

In a new QSO Memo dated September 20, 2023, the Centers for Medicare and Medicaid Services (CMS) announced updates coming to the Nursing Home Compare Staffing and Quality Measures. These changes are coming in tandem with changes to the MDS which are effective October 1, 2023.

A couple important items to note:

  • Changes are coming to the CMS-671 and CMS-672. MDS Section G data has traditionally been used to populate the Resident Census and Conditions of Residents form, but Section G is being discontinued.
  • The information provided in this QSO Memo is separate from information provided in the proposed minimum staffing requirements issued recently.
  • The staffing rating methodology is going to be revised. CMS believes this will incentivize providers to submit accurate staffing data, and those who fail to submit data or submit erroneous data will be penalized in the form of the lowest score available related to turnover measures.

CMS Form 671 and Form 672

Survey-related forms are being changed based on the upcoming changes to the MDS. Due to Section G being removed from the MDS, fields on the CMS-672 form can no longer be completed, and these MDS-based fields are not used as part of the survey process any longer, anyway. Effective September 29, 2023, facilities do not have to complete fields F79-F145 and surveyors do not need to populate F79-93 in the survey system.

The following should still be completed:

  • Census Information (F75-F78)
  • Ombudsman Information (F146-F147)
  • Medication Error Rate (F148)

On October 22, 2023, the above fields will be relocated from the CMS-672 to the CMS-671. The CMS-672 will be removed at this time.

Staffing Measure Changes

Nurse staffing measures are currently adjusted using a case-mix methodology based on MDS items from RUG-IV Items in MDS Section G will be replaced by new Section GG items, which means CMS needs to change the case-mix adjustment method.

The staffing case-mix adjustment methodology will be based on the SNF PDPM in 2024. The staffing measure will be frozen for 3 months, beginning in April 2024, to allow for the transition.The new measures will be posted starting July 2024. The associated staffing rating thresholds will also be revised to maintain the same overall points distribution for impacted staffing measures, according to the Memo.

Penalty for Failure to Submit Staffing Data

Currently, any facility that fails to submit staffing data or submits erroneous data for staffing levels (HPRD) receives a 1-star staffing rating for the quarter in which the data was reported. CMS recognizes that providers who fail to submit data in order to calculate staff turnover have their turnover measures excluded from the staffing rating calculation, which means their score is not impacted. To incentivize providers to submit accurate data, beginning April 2024, the staffing methodology will be revised so that any provider that does not submit data or submits inaccurate data will receive the lowest possible score for the associate turnover measures.

Quality Measures Changes

Unlike the plan for the staffing measure, these changes won’t be made in July 2024. Instead, CMS will address the Quality Measures changes over time. Starting in October 2024, the Short-Stay functionality Quality Measure will be replaced with the new cross-setting functionality QM that is used in the SNF QRP. The above Long-Stay QMs will remain frozen until January 2025 to allow for data related to the equivalent measures to be collected. That’s a lot of changes to Nursing Home Compare on the way – starting next summer and proceeding into the start of the following year.

Read the CMS QSO Memo, “Updates to Nursing Home Care Compare Staffing and Quality Measures” (QSO-23-21-NH) for additional details.

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