Q: How do I know what determines my 2% annual payment reduction? I’ve received a non-compliance letter citing MDS reporting requirements, but it doesn’t provide details.
A: Failure to meet the requirements of the Skilled Nursing Facility Quality Reporting Program will result in a 2 percentage point reduction in the Annual Payment Update (APU). This can happen when the provider does not achieve an 80% threshold on the MDS reporting requirement.
Essentially, no less than 80% of the MDS assessments for a given data submission period must have 100% completion of the required SNF QRP standardized data elements.
To your point, a non-compliance letter will let you know that the threshold has not been met but does not describe the specific MDS data elements that were not submitted or “dashed.” The data elements used for reporting assessment-based Quality Measures affecting FY 2024 APU determination include Section GG discharge goal, bowel continence, certain diagnoses, height, weight, falls with major injury, pressure ulcers/injuries and drug regimen review.
Keep an eye on your SNF QRP QM reports. These are refreshed monthly and include facility-level and resident-level information for a single reporting period. Providers also have access to the SNF QRP Review and Correct report prior to each quarterly data submission deadline and the provided data should be reviewed for accuracy. Keep in mind that “triggering” for some measures is desirable while “triggering” for others is not. Erroneous records can be corrected as long as the deadline for corrections has not passed.
Identifying which data elements are incomplete is necessary to review processes and avoid future situations where data may not be submitted.
Please send your payment-related questions to Eleisha Wilkes at [email protected].
From the October 2023 Issue of McKnight's Long-Term Care News
