Clearing Up the SNF Quality Reporting Program Confusion

Regulation | September 11, 2017

The Skilled Nursing Facility Quality Reporting Program (SNF QRP) has experienced a number of implementation issues since it began October 1, 2016 leaving SNFs grappling with making sense of how to comply.

In the past several weeks, there have been a number of communications from CMS regarding issues, corrections, changes to reporting periods and implementation of the 2% payment reduction for “non-compliant” SNFs. In addition, CMS has finalized its changes to the program for FY2018 and FY2020. The result is a lot of dates and steps for SNF staff to wrap their heads around. 

Below we attempt to clear up some of the confusion given the number of dates, deadlines, submissions, and reports:  

  • Effect on Medicare Fee-For-Service (FFS) Payments beginning 10/1/2017: For SNFs who received a non-compliance letter from CMS prior to July 18, 2017, the 2% payment reduction will take effect 10/1/2017 because it is based upon data reported for 10/1/2016 – 12/31/2016.  Data for this time period was due June 1, 2017.  Providers who received a non-compliance letter from CMS had until August 13 to request reconsideration of their Q4 2016 data.

  • Technical Coding Issues Identified for CY2017 Data Delays Submission Deadline:  In August, CMS identified two technical coding issues that impacted measure results for Calendar Year 2017 MDS data.  The measure results were incorrectly calculating and reported to SNFs in their “Review & Correct reports” and the “Confidential Feedback Reports.” are related to MDS data for calendar year 2017.  Normally, CMS has separate quarterly deadlines for submitting and correcting each quarter of MDS data.  Due to the technical coding issues, CMS has notified SNFs that ALL Calendar Year 2017 MDS data now must be submitted by May 15, 2018.  As of Sept. 5, one of the two issues has been resolved related to use of a modified record for a patient stay for calculating measures.  The updated Review and Correct Reports are now available in the CASPER system for SNFs to review and now include the recalculated results for the MDS-based quality measures.  The second issue identified by CMS is related to the functional assessment and care plan measure and is not expected to be resolved until later in the year.  This means that SNFs will not receive their Confidential Feedback Reports until December 2017 (previously anticipated for release in October 2017)
  • Data collection and submission deadline tables for MDS data reported in calendar years 2018 and 2018, and impacting FY2019 and FY2020 Medicare FFS rates can be accessed at: FY2019 tables and FY2020 tables.
  • CMS has posted its August 7 SNF Review and Correct Reports Refresher Webinar Video on YouTube.