Updates to PRF NH Infection Control Incentive Payments

Regulation | October 19, 2020 | by Nicole Fallon

The first round of $400 million in Provider Relief Fund Nursing Home Infection Control Incentive Payments will be rolling out to providers shortly--estimated to be the week of October 27 -- under a slightly revised approach by the U.S. Department of Health and Human Services (HHS). The main focus of the changes is on the mortality measure calculation and its impact on final incentive payments. 

To be eligible for an Infection Control Incentive Payment, providers must first meet two "gateway" criteria: 1) the nursing home's infection rate must be lower than that of the infection rate in their county; AND 2) the nursing home's mortality rate must be less than 10% for all residents in their facility that contracted COVID-19 (includes both in-facility acquired infections as well as COVID admissions).

For those providers who pass through the two gateways, HHS has changed its approach to the Infection Control Incentive Payments in a couple of ways. First, instead of setting aside 80% of each incentive pool for performance on the infection control measure and 20% for the mortality measure, 100% of each round of incentive funds will "be available to providers that have positive performance on the infection measure." This is an improvement from the prior approach, which would have disadvantaged those nursing homes with no infections. Secondly, a provider's incentive payment will be calculated looking at its infection measure performance modified based upon its mortality measure performance. HHS will conduct outreach to those eligible nursing homes with one or more deaths during the performance period to determine which were deaths due to in-facility acquired infections vs. COVID admissions. The mortality measure may impact the final incentive payment as much as 20% upward or downward. It should also be noted that the mortality measure will be risk adjusted based upon nursing home demographic data such as age, gender, and resident type (Medicare-covered vs. long term residents). We appreciate that HHS has sought input from LeadingAge on the program and made some revisions in response to concerns raised, especially on the mortality measure. 

Under the Infection Control Incentive Program, roughly $400 million in incentive payments will be distributed each month based upon monthly performance, and there will also be a final incentive payment that looks at a nursing home's aggregate performance from August 31 - Decmeber 27, 2020. This is the proposed performance and payment timeline for the program.

Performance Period

Performance Period Data Range

Weeks in performance period

Payment Period

September 2020

Aug. 31 – Sept. 27

4

October 2020

October 2020

Sept. 28 – Nov. 1

5

November 2020

November 2020

Nov. 2 – 29

4

December 2020

December 2020

Nov. 30 – Dec. 27

4

January 2021

Aggregate

Aug. 31 – Dec 27

17

February 2021

HHS estimates that 65-70% of all nursing homes will receive an incentive payment in October under the new approach. HHS is currently finalizing its brief on the program and LeadingAge will share it as soon as it is available. LeadingAge has also asked HHS to consider providing eadditional detail on the specific data and calculations that go into the two measures for the program; as well as publishing information on which nursing homes received incentives and the amounts of the incentives.