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DOH Finalizes 2015 NH Quality Pool Methodology

The Department of Health (DOH) has finalized the scoring methodology for the 2015 Nursing Home Quality Initiative (NHQI), which was e-mailed to administrators on July 27.  As previously reported by LeadingAge New York, NHQI Medicaid payment adjustments for 2013 and 2014 are on hold until DOH publishes authorizing state regulations on an emergency basis.  We are advocating for timely action.

DOH had proposed several revisions to the NHQI for 2015 including changes to the point distributions; a new protocol on quality measures (QMs) for small sample sizes; new antipsychotic, staffing hours and staff turnover measures; and changes to the potentially avoidable hospitalizations (PAH) measure.  LeadingAge NY’s comments offered general support for many of the proposed changes but raised specific questions and concerns on staffing hours reporting, the proposed turnover measure and the avoidable hospital use measure.

The proposed changes and their disposition in the final methodology are as follows: 

1.       Replace the current long stay antipsychotic use measure with a measure from the Pharmacy Quality Alliance which is limited to the Alzheimer’s and dementia population. This revision was adopted;

2.       Replace the CMS Five-Star staffing rating (which is based on a two-week snapshot) with an annualized staffing hours measure taken from Medicaid cost reports.  Due to concerns about the data and timing of the change, DOH plans to publish this measure for information only for the 2015 NHQI and to continue using the Five-Star staffing rating in the 2015 scoring;

3.       Institute a new direct nursing employee turnover measure using cost report data. Due to data concerns and timing, this too will be published for information only for the 2015 NHQI;

4.       Revise the PAH measure from being based on long stay days to one based on the number of stays contributed by each long stay resident. This change will not be made; the measure will continue to use long stay days as the denominator. However, it will be calculated for each quarter, then averaged to create an annual average rather than being calculated annually;

5.       Use a quintile method rather than an 85 percent cutoff to assign points for the long stay resident pneumococcal vaccination measure. This revision was adopted;

6.       Substitute the quarterly statewide average when a facility has one quarterly denominator of less than 30 in any risk adjusted QM. This change will not be made; DOH will use an average of the facility’s QM data for the remaining three quarters; and 

7.       Change the overall point distributions in the NHQI to increase the total QM points from 70 to 75 and decrease the compliance points from 20 to 15. However, since the new employee turnover measure is not being included in the 2015 scoring, this change is not being made. 

LeadingAge NY had also expressed concerns with the delays in finalizing the methodology each year. In response, DOH has said that they will plan to release the 2016 NHQI methodology in January 2016.

Members are once again reminded that the 2014 cost report must be completed, filed and certified by Aug. 14 (for calendar year filers) and Nov. 13 (for fiscal year filers) to be eligible for 5 NHQI points under compliance and 5 additional points under the QMs. Each member facility should verify well before the due date that any individual(s) who would be responsible for certifying the cost report have active Health Commerce System accounts.      

Contact: Dan Heim, dheim@leadingageny.org, 518-867-8866