In a June 25, 2020 QSO Memo, the Centers for Medicare & Medicaid Services (CMS) made multiple announcements regarding Nursing Home Compare and the end to emergency blanket waivers that were enacted as part of the COVID-19 Public Health Emergency (PHE).
First, let’s look at the changes related to the Payroll-Based Journal (PBJ) and staffing data submission. There are two major items to be aware of – the end of the emergency blanket waiver for submitting data through PBJ, and the deadlines for which facilities need to submit this data by going forward.
Immediate End to Blanket Waiver for Submitting Staffing Data to Payroll-Based Journal System (PBJ)
- CMS had waived the requirement for nursing homes to submit their staffing data to the Payroll-Based Journal System. The QSO Memo states that effective immediately, the blanket emergency waiver for submitting staffing data through PBJ is ended.
- CMS notes that since facilities were not submitting data, it cannot update the Payroll-Based Journal staffing measures or Staffing Domain star-ratings for the next scheduled update on July 30th. As a result, on July 29, 2020, staffing measures and star ratings will be held constant. The data used for those ratings will be based on data that was submitted for Calendar Year 2019 Quarter 4 (October 2019-December 2019).
- Facilities that had been automatically downgraded to a 1-star rating due to missing a PBJ submission timeframe or not meeting the criteria for having an RN onsite have not been able to correct this automatic downgrade due to the waiver being in place. Facilities automatically downgraded to a 1-star will have the downgrade removed but will have their staffing measures and ratings temporarily suppressed.
PBJ Submission Requirements Moving Forward
- As of the publication of this QSO Memo – June 25, 2020, effective immediately, facilities are required to being submitting their data through the PBJ system.
- Facilities are required to submit staffing data through the PBJ system by August 14, 2020 for Calendar Quarter 2 (April 2020-June 2020).
- Staffing measures and ratings will be updated in October 2020 using the data that has been submitted by the August 14, 2020 deadline.
Another area outlined in the QSO Memo reflects another domain of the Five-Star Quality Rating and information that is posted on Nursing Home Compare, the Quality Measures Domain. This information will be updated using data from prior to the PHE and is not being held constant.
Quality Measures Data
Since the requirements for submitting MDS data and completion timelines were waived by a blanket emergency waiver, CMS notes in the QSO Memo that the Agency is concerned that assessments conducted after January 1, 2020 have been impacted by that waiver and the COVID-19 PHE.
- On July 29, 2020, QMs will be based on the data collection period ending December 31, 2019. CMS notes that it believes that data used from assessments conducted prior to January 1, 2020 can still be used for calculating the QMs.
- QMs based on data collection periods prior to December 31, 2020 will continue to be updated until the data reaches December 31, 2019.
- The Quality Measure ratings are not being held constant. CMS notes that the provider’s quality measure rating can be updated using that data.
The final area that is mentioned in the QSO Memo – albeit with not many details – is in regard to the Health Inspection Domain and associated ratings. CMS announced that the Health Inspection ratings would be held constant on Nursing Home Compare due to the Agency’s prioritization of certain survey types, but notes in this QSO Memo that it will restart inspection ratings “as soon as possible.” As you are aware, State Agencies are required to complete Focused Infection Control Surveys of every nursing home in the United States by July 31, 2020, and as more states move through their reopening processes, this moves the needle towards restarting routine survey and certification surveys.
Read the complete QSO Memo, “Changes to Staffing Information and Quality Measures Posted on the Nursing Home Compare Website and Five Star Quality Rating System due to the COVID-19 Public Health Emergency” (Ref: QSO-20-34-NH).