Federal officials are considering significantly expanding how much information nursing homes must record in the Minimum Data Set, potentially adding reporting for patients outside of Medicare to requirements.
The Centers for Medicare & Medicaid Services has asked for input on its plans to possibly extend the Skilled Nursing Facility Quality Reporting Program to include all residents receiving short-term nursing home care — regardless of their payer.
For facilities with large Medicaid populations, that could mean an explosion of data collection and submission responsibilities and careful strategizing to avoid payment deductions. Currently, MDS data is submitted only for patients whose stays are covered by fee-for-service Medicare.
“I have worked with many SNFs who have less than 10% Medicare caseload and over 80% Medicaid,” said Jessie McGill, RN, curriculum development specialist for the American Association of Post-Acute Care Nurses “These facilities may have very different impacts if CMS uses all payers [compared] to a SNF, LTCH or IRF that has over 50% Medicare Part A residents.”
A high Medicare Advantage caseload also would increase required data collection and reporting time.
Because Medicare covers less than 50% of all nursing home stays, CMS has said it wants to create a larger data pool to measure provider quality.
“Due to the declining numbers of beneficiaries with Medicare FFS benefits, collecting data on all residents, regardless of payer, supports CMS’ mission to ensure quality care for all individuals and provides the most robust and accurate representation of quality in the SNF setting,” the agency said in announcing an October listening session on the proposal.
The agency, through RTI International, is asking clinical staff, MDS coordinators, administrators and software vendors to weigh in on its proposal. CMS has asked for specific input on:
- Data collection and submission scenarios that might occur for all residents regardless of payer, including stays that are interrupted by hospitalization or leaves of absences.
- Other than a change in payer and a significant change in condition, clinical scenarios or other resident “changes” CMS should consider that might trigger a new assessment.
- Considerations for how the data collected on all residents regardless of payer might be used.
McGill told McKnight’s Long-Term Care News that the proposal also would require additional reporting outside QRP measurements, including Standardized Patient Assessment Data Elements.
“Some of these data elements are already completed on the MDS for all residents, such as race and ethnicity, but others only apply to the Medicare Part A residents — such as the provision of the reconciled medication list at discharge and health literacy,” McGill said. “These items are currently completed on either the Medicare 5-day and/or the Part A PPS Discharge assessment.”
Such elements are critical to the SNF QRP program because they tell CMS whether a facility met a reporting threshold that required 90% of all MDS submissions to include 100% of the mandatory data elements. If the threshold, increased in fiscal 2024, is not met, facilities can receive a 2% deduction to their annual Medicare payment update. That could be true even if dashes were used primarily in non-Medicare beneficiaries’ MDS data.
“This is not a small task. The list of required data elements is 13 pages long,” McGill said, referring to FY 2027 quality elements that require reporting in calendar year 2025.
If any of the required MDS items are dashed, that assessment counts against the reporting threshold.
McGill noted two major concerns, in addition to time needed for completion.
CMS currently makes no exceptions to the reason MDS items are dashed, including for resident refusal, such as on a required weight check. The number of dashes could grow with more patients included, leaving facilities more vulnerable to payment reductions.
And, she said, not all of the data elements apply to long-term residents who have no plans to discharge. That could skew the measure results if included in measures such as discharge function score or the two Section GG outcome measures, the discharge self-care core and discharge mobility score.
