NF NSGO QI Program Update · presentation for questions (or email me later) General Information •...

NF NSGO QI Program Update

Trent Brown, MOT, OTR/L, ATP, BCGNursing Facility QI Program Manager

General Information

• I will be going over a lot of information

• Please take notes of any questions you may have

• If not covered, there will be time at the end of the presentation for questions (or email me later)

General Information

• The contract states, in part: “The CONTRACTOR shall implement a quality improvement program in compliance with UAC R414-516.”

• Failure to submit the compliance form is considered a breach of contract.

• It is essential that all facilities submit the required information timely, completely and accurately.

General Information

• R414-516-3(4) states: “Each program shall submit to the Division a compliance form, using the current Division form, within 30 days of the end of the calendar year…

• The Department is considering changing this to the end of January

***Updated Email: qiupl@Utah.gov***

General Information

• If late or after audit, the facility doesn’t have the required points• “earn the number of QI points not achieved from

that calendar year in addition to the required QI points the subsequent calendar year”; and

• “submit to the Division a plan of correction that details compliance with the QI Program.” (within 10 business days of request from the agency) (See R414-516-9(1))

Audit Information

(4) The Division may audit a program at any time to ensure compliance.(b) When an audit is performed, all documentation requested by

the Division shall be postmarked or demonstrate proof of delivery to the Division within 10 business days of the request.

(c) Failure to submit the requested documentation in a timely manner shall result in the program forfeiting the QI points for the specific QI program category being audited.

(d) If an audit is completed, as applicable, the findings of the audit shall supersede the program's reported QI points.

Audit Information

• When audited, you will receive a notice of audit per R414-516 with detailed requests

• All audit information requested must be emailed/ postmarked within 10 business days of the notice (R414-516-9(4))

Audit Information

• If an audit occurs and a facility cannot verify claimed QI points, those points will be removed from the total

• If a facility has points removed, it may still demonstrate compliance by having earned the minimum requirement in other areas (if originally submitted)

• It is beneficial to earn as many points possible for situations where points may be removed during an audit

Audit Information

• Why Audit?

• Aren’t we doing enough?

• Isn’t “intent” good enough?

• Auditing the QI program gives the industry and the department “teeth” to demonstrate improved quality in nursing facilities receiving Gap Payment

QI PointsPre-Audit Total Industry Claimed QI Pts. 919Average Pts. Per Facility 20.4Post-Audit

Total Industry QI Pts. 800QI Points Reduced 119Average Pts. Per Facility 17.8Number of Facilities with Reduced Pts. 27% Facilities with Reduced Pts. 60%

Points/Percentages by CategoryQuality Awards and Casper Reduced 67Percentage of Overall 56.3%

Infrastructure and Renovation Reduced 24Percentage of Overall 20.2%Staffing and Direct Resident Services Reduced 28

Percentage of Overall 23.5%

Facilities Compliant with 2018 44 98%Facilities Compliant with 2019 39 71%Facilities Compliant with 2020 and beyond 33 76%Facilities >21 Points (compliant for 2 consecutive years) 9 20%Facilities earning 30 or more QI Points 1 2%

Pre-Audit Avg. Avg. Points Removed Post-Audit Avg.20.4 2.6 17.8

2018 QI Issues

READ THE RULE:

• The details found in the rule are the definitive source

• Many NF’s this last year lost QI points during the Audit process because they didn’t understand a specific areao Points were claimed because they “heard” about a

particular program/area where points could be earnedo Please, please, please… Read the Rule!

CASPER

1. Correct Dates

2. Long Term vs. Short Term

3. 20% Improvement

CASPER

401K/Pension

1. 401K Policy

2. Company Match

3. Ledger

401K/Pension

5 Meal Program

1. MealSchedule

2. Quarterly Evidence

3. Staffing for Schedule

5 Meal Program

Provided weekly menu and staff schedule for each quarter

Staff Retention

1. Calculation

2. Staff Members retained/terminated

Staff Retention

Consistent Assignment

1. Schedule

2. Schedule must be marked outlininghalls/sections

3. Evidence of worked hours

Consistent Assignment

Consistent Assignment

Activities

1. Residents for calculation

2. Documentation as required in Rule (POC, weekly)

Activities

(blank copy of documentation is okay)

Activities

Snack

1. List of residents in calculation

2. Documentation (beverage and food)

Additional Audit/Compliance Helps

• FRV Age is found on the website:

https://health.utah.gov/stplan/longtermcarenfqip.htm

Make sure your FRV information is current/updated if you are looking to claim those points

• QI Program not required for residents with a LOS < 14 days

UPL QI Program Updates andChanges

• R414-516-3(5)

The Division does not require a provider that enters the NF NSGO UPL program for only part of a calendar year to comply with the QI provisions in the first program calendar year.

UPL QI Program Updates andChanges

• The UPL QI program has 5 sections instead of 3 better classifying where points can be earned• Quality Awards• Construction and Renovation (unchanged)• Direct Resident Services• Quality Metrics• Staffing (same point system moved from Direct

Resident Services)

UPL QI Program Updates andChanges

• 68 available QI Points compared to 69 Previously

• 3 (6 previously) QI points required in Direct Resident Services section in 2019 and 4 (7 previously) required in 2020 and beyond (at this time)

Quality Metrics (R414-516-7) ***NEW***

• Quality Metrics (QM) changes allow the NFs to use metrics as a way to earn QI Points

• 6 metrics were chosen as indicators of high quality services

• These metrics are added into the QI Program and replace the CASPER portion of the “Quality Award and Casper” section.

Quality Metrics (R414-516-7) ***NEW***

• Replacing the Majority of CASPER section

• Measuring 6 areas based on 5 year historical averages• 5-Star CMS Rating for Quality Measure (QM) = 3.62• Urinary Tract Infections (L) = 6.68%• Pressure Ulcers (L) = 6.15%• Falls with Major Injury (L) = 4.17%• Adjusted Nurse Staffing Hours = 3.81• Scope and Severity of Deficiencies = 3.57

Quality Metrics (R414-516-7) ***NEW***

• All Data is imported from the CMS Archive website

https://data.medicare.gov/data/archives/nursing-home-compare

Quality Metrics (R414-516-7) ***NEW***

• All these metrics are already being used and evaluated by CMS

• The expectation is, as UPL monies continue to be invested into nursing homes, these metrics improve

• 4 of 6 of the metrics being used were previously being used in the QI program

Quality Metrics (R414-516-7) ***NEW***

(1) Quality Metric (QM) scores equal or better than industry average (target)

b) Points are earned as follows:(i) >4 QM at or above target = 4 QI points(ii) 4 QM at target = 3 QI points(iii) 3 QM at target = 2 QI points

c) Points for improvement may be earned as follows:(i) improvement in > 4 targets = 2 QI points(ii) improvement in 4 targets = 1 QI point

Quality Metrics (R414-516-7) ***NEW***

• QI Points may be earned in the quality metrics section but it is not a requirement at this time

• As always, the QI points may be earned in any section(s) the facility desires as long as the minimum are earned in the Direct Resident Services

• Essentially, the QI metrics are an additional area where QI points can be earned

Quality Metrics by the Numbers

• The Division looked at historical data using the aforementioned quality metrics

• The historical data was presented to the UHCA Board as an informational item

• The data provides specific information on how SNF’s in our state are improving quality in these areas

Quality Metrics by the Numbers

• The Division compared NSGO facilities to Non-NSGO (including and excluding Medicare/VA facilities)

• The Division compared the 5 year overall historical averages

• The Division also compared year by year averages looking for improvement over time

Quality Metrics by the Numbers

• The numbers used for the QI Program were based on the 5 year historical averages of all facilities (excluding Medicare/VA facilities)

• The following graphs represent the findings

Calculation for Nursing Hours

(Hours Reported/Hours expected) x hours national average

• Hours Reported = CMS671 form completed during most recent survey

• Hours Expected = Staffing value for each facility based on RUG levels of residents in the facility in the quarter closest to survey date (Resident A requires 3 hours, whereas Resident B requires 5 hours)

• Hours Adjusted = mean across all facilities of the reported hours per resident day for a given staff type

(includes RN+LPN+nurse aide)

Calculation for Scope & Severity

A = 2B = 3C = 4D = 3E = 4F = 5G = 4Etc.

CASPER Measures

• Long Term Residents (Length of Stay = > 100 days)

• Pressure Ulcer for High Risk meeting the following criteria:

• Impaired Bed Mobility or Transfers,• Comatose, or• Malnutrition

and

• Stage II-IV Pressure Ulcer and not on the admission assessment

CASPER Measures

• Long Term Residents (Length of Stay = > 100 days)

• Fall must include a diagnosis of the following:

• Bone Fracture,• Joint Dislocation,• Closed Head Injuries with Altered Consciousness, or• Subdural Hematoma

(exclusions: skin tears, abrasions, superficial bruises, etc.)

Quality Metrics by the Numbers

• The Division has the ability to separate each facility and compare Metrics to the Baseline

• This available on the website at:

https://health.utah.gov/stplan/longtermcarenfqip.htm

(Click on QM by Facility)

Example: High Risk Residents with Pressure Ulcer

Quality Metrics by the Numbers

• The Division also compares the number of facilities performing “above average” in the various metrics

Conclusion

• As UPL dollars increases, so has the scrutiny from many sources (e.g., CMS, UOIG, GOMB, legislature)

• As the UPL program has accelerated, the QI Program is a way the division can measure quality and quantify the effectiveness of the UPL program to interested parties

(in Millions) 2013 2014 2015 2016 2017 2018 Grand TotalNF NSGO UPL Payment $4.1 $10.2 $22.3 $55.7 $71.5 $89.0 $252.9

Questions ?

Trent Browntrentbrown@utah.gov