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CMS Clarifies SNF Quality Reporting Program Requirements

The Centers for Medicare and Medicaid Services (CMS) has just issued a tip sheet summarizing the status of the Skilled Nursing Facility (SNF) Quality Reporting Program (QRP) during the COVID-19 Public Health Emergency (PHE). It also provides guidance on SNF quality data submission requirements starting July 1, 2020, now that the temporary SNF QRP exemptions from the COVID-19 PHE have ended.

Quality data for the SNF QRP are collected and submitted using the Minimum Data Set (MDS)/ Resident Assessment Instrument (RAI) and Medicare fee-for-service (FFS) claims. On March 27, 2020, CMS announced that it was temporarily lifting the requirements for SNFs to report QRP data to assist them during the COVID-19 PHE. Under this relief, SNFs were excepted from reporting data on measures and standardized patient assessment data required under the QRP for the following periods:

  • Oct. 1, 2019 – Dec. 31, 2019 (Q4 2019);
  • Jan. 1, 2020 – March 31, 2020 (Q1 2020); and
  • April 1, 2020 – June 30, 2020 (Q2 2020).

The temporary exception for SNF quality reporting requirements ended on June 30, 2020. Starting on July 1, 2020, SNFs are expected to resume timely quality data collection and submission of measure and patient assessment data for the MDS/RAI. For this purpose, the MDS should be submitted for all new admission records and discharge records occurring on or after July 1st. The QRP submission deadline for Q3 data (July – September 2020) is Feb. 15, 2021, while Q4 data (October – December 2020) is due May 15, 2021. Timely submission and acceptance requirements of MDS data to meet the 80 percent threshold are unchanged. SNFs must submit at least 80 percent of the necessary data to calculate the SNF QRP quality measures. The compliance threshold calculation is based on the number of MDS assessments submitted with complete data on each MDS assessment used for the SNF QRP. There are no additional submission requirements for Medicare FFS claims data.

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