What therapy teams should know about proposed changes to the SNF quality reporting program

The time is here.

The time is now for us all understand the upcoming shifts to the skilled nursing facility quality reporting program (SNF QRP).

This is not simply a program for one department to understand. In order to effectively and efficiently code to meet the proposed changes and standards we will all have to work together to achieve accuracy.

To begin, what is the skilled nursing facility quality reporting program?

The SNF QRP is a pay-for-reporting program. SNFs that do not meet reporting requirements are subject to a 2 percentage point reduction in their Annual Payment Update (APU). 

In the FY 2024 SNF PPS proposed rule, CMS is proposing the adoption of three measures in the SNF QRP, the removal of three measures from the SNF QRP, and the modification of one measure in the SNF QRP. In addition, this proposed rule would also make policy changes to the SNF QRP, and begin public reporting of four measures.

Getting up to date

So, what’s new?

Let’s begin with function and as you review below, consider how your therapy team can continue to foster a culture of interdisciplinary MDS coding accuracy for the patients you serve. 

Discharge Function Score Measure

CMS is proposing the adoption of the Discharge Function Score (DC Function) measure beginning with the FY 2025 SNF QRP. 

Measure details: This measure assesses functional status by assessing the percentage of SNF residents who meet or exceed an expected discharge function score, and uses mobility and self-care items already collected on the Minimum Data Set (MDS). 

This measure would replace the topped-out process measure — the Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment/a Care Plan That Addresses Function (Application of Functional Assessment/Care Plan) measure, as discussed below. 

CoreQ: Short Stay Discharge Measure

Secondly, CMS is proposing the adoption of the CoreQ: Short Stay Discharge (CoreQ: SS DC) measure beginning with the FY 2026 SNF QRP. 

We first shared with you details of CoreQ in an April 2022 edition of “Rehab Realities.”

Measure details: This measure calculates the percentage of individuals discharged from an SNF, within 100 days of admission, who are satisfied with their SNF stay.  

The questionnaire that would be administered under the CoreQ: SS DC measure asks individuals to rate their overall satisfaction with their care using a five-point Likert scale.  The areas of care include: staff, the care received, recommending the facility to friends and family, and how well their discharge needs were met.

What is proposed to be removed?

To begin, CMS is proposing to remove the Application of Percent of Long-Term Care Hospital (LTCH) Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (Application of Functional Assessment/Care Plan) measure beginning with the FY 2025 SNF QRP. 

Why?CMS is proposing this measure removal for two reasons.  

First, the Application of Functional Assessment/Care Plan measure meets the conditions for measure removal factor one: measure performance among SNFs is so high and unvarying that meaningful distinctions in improvements in performance can no longer be made. 

Second, this measure meets the conditions for measure removal factor six: there is an available measure (the proposed DC Function measure, discussed above) that is more strongly associated with desired resident functional outcomes.

Next, CMS is proposing to remove the Application of the IRF Functional Outcome Measures: Change in Self-Care Score for Medical Rehabilitation Patients (Change in Self-Care Score) measure; and the Change in Mobility Score for Medical Rehabilitation Patients (Change in Mobility Score) measure beginning with the FY 2025 SNF QRP. 

Why?

CMS proposes to remove these two measures because these measures meet the condition for measure removal factor eight: the costs associated with a measure outweigh the benefits of its use in the program. Additionally, these measures are similar or duplicative of other measures within the SNF QRP.

Threshold increases for reporting

CMS is proposing to increase the SNF QRP Data Completion thresholds for the Minimum Data Set (MDS) Data Items beginning with the FY 2026 SNF QRP. 

CMS proposes SNFs must report 100% of the required quality measure data and standardized resident assessment data collected using the MDS on at least 90% of the assessments they submit to CMS. Any SNF that does not meet the proposed requirement that 90% of all MDS assessments submitted contain 100% of required data items, will be subject to a reduction of 2 percentage points to the applicable FY annual payment update beginning with FY 2026.

The time now engage more fully as an IDT in documentation and coding. Review above with your teams, start conversations on how we can work more cooperatively across departments and let us collectively move into these season of change with a greater focus on quality and measures of care. 

Renee Kinder, MS, CCC-SLP, RAC-CT, is Executive Vice President of Clinical Services for Broad River Rehab. Additionally, she serves as a member of American Speech Language Hearing Association’s (ASHA) Healthcare and Economics Committee, is a member of the University of Kentucky College of Medicine community faculty and is an advisor to the American Medical Association’s Current Procedural Terminology CPT® Editorial Panel. She can be reached at [email protected].

The opinions expressed in McKnight’s Long-Term Care News guest submissions are the author’s and are not necessarily those of McKnight’s Long-Term Care News or its editors.