CMS Quality Safety & Oversight Memorandum
MEMO NUMBER: 18-17-NH
PUBLISHED: April 6, 2018
CMS LISTING: Quality, Safety and Oversight Letter 18-17-NH
The April 218 QSO memorandum 18-17-NH from CMS introduced three significant evolutions of the PBJ program and moved the program from a focus on data collection to a focus on outcomes – particularly the staffing Five Star rating.
Staffing Five Star rating on the Nursing Home Compare Quality Rating System (QRS)
Starting in April, 2018, CMS will use PBJ data to determine each facility’s staffing measure on the Nursing Home Compare tool on Medicare.gov website, and calculate the staffing rating used in the Nursing Home Five Star Quality Rating System.
In a parallel step, beginning on June 1, 2018, facilities will no longer be required to complete the staffing portion of the CMS-671 form found on page 2. The 671 form was the staffing data collection tool before the implementation of payroll-based journal.
Staffing Data
CMS began conducting audits aimed to verify that the staffing hours submitted by facilities are aligned with the hours staff were paid to work over the same timeframe. Some common errors identified through audits include:
- Exclude time for meal breaks
- Each employee must have their own unique identifier (ID)
- Exclude hours for staff that provide care to individuals in non-certified areas of a larger institution or institutional complex that houses the certified facility
Facilities whose audit identifies significant inaccuracies between the hours reported and the hours verified will be presumed to have low levels of staff – which then will result in the facility receiving a one-star staffing rating. A one star for Staffing will also reduce the facility’s overall (composite) rating by one star for a quarter.
Requirement for RN Staffing
CMS is placing importance on facilities fulfilling the requirement to have an RN onsite at least 8 consecutive hours a day, 7 days a week under sections 1819(b)(4)(C) and1919(b)(4)(C) of the Act, and 42 CFR §483.35(b)).
From PBJ data, CMS observed recurring instances or aberrant patterns of days with no RN onsite. For example, based on the data submitted for Calendar Quarter 3, 2017, approximately 6% of facilities that submitted complete data had 7 or more days where no hours for RNs were reported. Also, approximately 80% of all days with no RN hours were weekend days.
Therefore CMS added a penalty for facilities reporting 7 or more days in a quarter with no RN hours – they will receive a one-star staffing rating, which will drop their overall (composite) rating by one star for that quarter.