As part of its initiative to increase Survey & Certification efforts, CMS outlined two new survey practices in an S&C letter released on April 18, 2014, “Focused Minimum Data Set (MDS) and Dementia Care Surveys.” The Agency notes that it is planning to conduct two short-term focused reviews of the survey processes surrounding dementia care, MDS 3.0 accuracy and care planning in nursing homes. Currently, five State Agencies are slated to participate in this initiative.
New Dementia Care Survey Pilot for Nursing Homes
Earlier this month, CMS announced that it had met its goal of reducing the national prevalence of antipsychotic drug use in nursing homes by 15.1%. Since the goal was achieved, CMS noted that it would be making new goals. In May 2012, CMS had provided new guidance on dementia care and surveyors have been assessing compliance at F-309 and F-329 using that new guidance, but there is still more to be done. The next step CMS will be taking is to run a pilot program to take a deeper look at the process nursing homes use for prescribing antipsychotic medications, in addition to looking at other dementia care practices. At the conclusion of this pilot test, CMS hopes to be able to streamline the current survey process and give surveyors a better way to accurately identify and cite deficient practices related to dementia care.
CMS will be identifying the nursing homes that will be surveyed. This survey process will include a detailed review of dementia care in nursing homes, including resident-level and organization-level process reviews. This will enable a full review and documentation of dementia care practices in nursing homes.
New Minimum Data Set (MDS) Accuracy Survey Pilot for Nursing Homes
In this S&C letter, CMS notes that although the primary purpose of the MDS is to provide clinical information for individualized care planning and delivering person-centered care, that this information is also used for RUG scores, Medicare (and sometimes Medicaid) payment rates and quality monitoring, so accuracy of the MDS information is essential on many levels.
CMS will be identifying the nursing homes that will be part of this pilot program for survey. This survey will focus on evaluations of MDS assessments and the care plans associated with these assessments. The OIG has been pressuring CMS to reduce fraud and waste, and part of its 2014 Work Plan includes reviews of Medicare Part A billing by SNFs and questionable billing patterns for Part B services during nursing home stays.
Any deficient practices that are identified by surveyors during these two pilot programs will result in citations. If there are additional care concerns that are identified, then they will be investigated or referred to the SA as a complaint. This is effective immediately.