CMS Payment Reduction Warnings Fall Silent

According to the Centers for Medicare and Medicaid Services (CMS), skilled nursing facilities (SNFs) must report 100 percent of the data elements necessary to calculate the SNF Quality Reporting Program (QRP) measures on at least 80 percent of the MDS assessments submitted for the program year. SNFs that do not meet this requirement are subject to a 2-percentage point reduction in their Annual Payment Update (APU). Prior to Sept. 9, 2018, facilities were responsible for verifying that the MDS items used for QRP were complete and submitting corrections for any MDS item used for QRP that was encoded with a dash. After Sept. 9, 2018, CMS released payment reduction warnings that would notify a submitter that a dash used in the MDS item may result in a payment reduction of 2 percentage points for the affected payment determination (error codes 3897, 3907, and 3908). Error code 3891, while not a dash warning, advises the submitter that there needs to be at least one discharge goal encoded on the MDS.

Even after introducing four new error codes, not all QRP MDS items have a consistency check. 31 percent, or about one-third of the MDS items used for QRP, do not have an error code warning, placing facilities who rely solely on these warnings at risk for the 2-percentage point reduction in their APU. Click here for a tool that provides details of the MDS items used for QRP, the type of assessment those items are included on, and the presence or absence of an error code warning. The rows highlighted in yellow represent the MDS items that do not have a consistency check, and therefore facilities will need to manually verify completeness to avoid the 2-percentage point reduction penalty.

CMS does plan for a staggered release of the additional error code warnings that will ultimately cover all the MDS items used for QRP. Until that time, do not rely on just the error code warnings to ensure that your facility avoids this costly penalty. Establish a procedure for ensuring MDS accuracy in the MDS items used for QRP. Train all members of the Interdisciplinary team that encodes the MDS on what items are necessary to be complete for QRP. Establish a process to verify that the MDS items are coded and accurate. Provide support at the highest level that ensures that all necessary documentation used to encode the MDS is available to staff at the time the MDS is completed.

Click here for the SNF QRP Spotlights and Announcements webpage.

Contact: Susan Chenail, schenail@leadingageny.org, 518-867-8383 ext. 116