When I was a kid, I loved getting dressed up for Halloween. I remember especially a clown (funny not scary) costume I got one year. I couldn’t wait to put it on and be transformed into another world. The candy was a bonus.
My absolute enjoyment of changing into a different character each year for a few hours was probably a harbinger of things to come later in life. Although professionally I am a nurse specializing in post-acute care regulatory affairs and education, on the side I am an amateur thespian.
You can routinely find me on the streets of Jonesborough, TN, dressed as an early 20th century baseball player leading a town tour, on stage at the Jonesborough Repertory Theater, or bringing a long passed on Jonesborough citizen to life in our annual cemetery play, “A Spot on the Hill.”
If you have been paying attention, you recognize that what the MDS has changed into this go round is significant. Item sets and RAI Manual revisions, now staffing calculations and quality measures specifications, have taken front and center. No clowning around here. However, the reason for this change is something to which we should also pay attention.
You are probably aware that the changes we are now acclimating to are the result of a piece of legislation that was signed into law back in 2014 called the Improving Medicare Post Acute Care Transformation Act, or IMPACT act.
In a nutshell, this legislation requires the reporting of standardized, interoperable patient assessment data with regard to quality measures and standardized patient assessment data elements (SPADEs), to allow for the exchange of data among post-acute and other providers, in order to improve Medicare beneficiary outcomes through shared decision making, care coordination and enhanced discharge planning. That’s a descriptive mouthful.
Unlike a mouthful of Halloween candy though, this delicious description is important to our understanding of the revised MDS data that we are now collecting. The SNF Quality Reporting Program (SNF QRP) relies on this standardized data to fulfill its responsibility to the IMPACT act. In other words, the SNF QRP creates the quality reporting requirement to which we owe MDS 3.0 v1.18.11.
Annually, the Centers for Medicare & Medicaid Services posts documents that indicate which items on the MDS contribute to this reporting requirement. With the implementation of v1.18.11 of MDS 3.0, the number of these data elements increased from 99 pre MDS 3.0 v1.18.11, to 230 in the revised data set. That’s 131 more MDS data elements that are required to be reported because of the SNF QRP.
Also, the FY 2024 SNF PPS final rule finalized a new reporting standard. Starting with MDS data collected in CY 2024, facilities will be required to submit 100% of the QRP required data on 90% of the MDS assessments submitted to IQIES.
This requirement carries with it some potentially hefty financial implications for SNFs that are non-compliant to the tune of a 2% reduction to the annual payment update or APU (adjusted market basket update). For FY 2024, that would mean a 6.4% update would be reduced to 4.4% that would then be further adversely affected by a 2.3% parity adjustment. Combined with Skilled Nursing Facility Value Based Purchasing (SNF VBP), sequestration and wage index adjustments, that’s not small potatoes.
And while the SNF QRP is the primary impetus for the MDS changes this year, some of the standardized data will also impact CMS’ other quality reporting efforts like the SNF VBP and Five-Star Quality Rating System. The SNF VBP shares the following measures with the SNF QRP: discharge function Score, healthcare associated infections that require hospitalization, falls with major injury, and discharge to community. The revised Five-Star rating will share the following: skin integrity post-acute pressure ulcer injury measure, discharge function score, and discharge to community.
One time my brother and I foolishly decided that we would pull a Halloween prank on a friend by soaping the windows on his car late at night. “Boy,” we thought, “will he be surprised.” We wore Halloween masks, just in case. A bit older at this point, I was now the werewolf.
As we were completing our mischief in the apartment complex parking lot, we noticed a young woman, apparently another tenant, walking toward us and realized that she was writing down our license plate number. Not to be discovered by our friend, we thought it would be helpful to explain to her what we were doing and that this was a friend’s car.
Forgetting our Halloween attire, as we ran after her to try to explain, we watched in dismay as she quickly disappeared into her apartment. Suddenly realizing that law enforcement may be our next surprise, we left in haste. A humorous, but real, lesson learned.
And so, here we are. It’s October 2023. All the hype is now reality. As we grapple with successful implementation of the revised MDS over the next several months, let’s be sure that we aren’t soaping any windows.
From the SNF QRP perspective, a single misplaced dash is all it will take to wake up in FY 2025 with an APU that is 2% less than everyone else’s. Nothing funny about that lesson.
The changes to the MDS are in the bag. It’s time for trick-or-treat. Are you prepared?
Joel VanEaton, BSN, RN, RAC-CT, RAC-CTA, is a master teacher and the executive vice president of PAC Regulatory Affairs and Education at Broad River Rehabilitation.
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.
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