HomeTown Medicare Call 5/11/2016 Kerry Dunning, MHA, MSH, CPAR, RAC-CT Chief Senior Services Officer Presented By:

2 GPS Healthcare Consultants SNF Medicare Webinar Topics 1.PEPPER 2.RAC Audits 3.SNF Updates

SNF PEPPER Released GPS Healthcare Consultants 3 If you have Swing Bed (not CAH) and SNF you need to download two reports PEPPER contains billing data for episodes of care in six “target areas” CMS has identified areas as being susceptible to fraud and abuse SNFs see how they compare with other SNFs in the target areas at a national, jurisdictional, and state level

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5 SNF PEPPER The PEPPER is used by CMS to identify potential improper billing practices SNFs/SWBs should use it to improve internal compliance programs Integrating PEPPER data into internal audit processes enable capture accurate data AND assist billing in “attracting” and/or withstanding audit Should use a Triple Check process always before billing SNF services

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8 SNF RAC Audits CMS’s concern is that SNFs with top quintile scores may be coding residents as receiving more services than were actually provided, or they may be providing more services than were actually needed. SNFs in the bottom quintile may be at risk for failing to provide adequate services in that target area to meet residents’ needs in a manner consistent with quality of care standards.

SNF RAC Audits 9 March 13 RAC audits restarted with SNF CMS asked RACs to investigate SNF Medicare therapy services to ensure they are provided per patient need and not per payment incentive A couple of hints: Triple check so you have clean claims Review your medical necessity documentation – nursing and therapy Review your RUG usage

SNF Updates 10 CMS added six new quality measures to Nursing Home Compare Three of these six new quality measures are based on Medicare-claims data submitted by hospitals First time CMS is including QMs that are not based solely on data self- reported by nursing homes. These three quality measures measure the rate of rehospitalization, emergency room use, and community discharge among nursing home residents CMS is nearly doubling the number of short-stay measures, which reflect care provided to residents who are in the nursing home for 100 days or less, on Nursing Home Compare. CMS is also providing information about key short-stay outcomes, including the percentage of residents who are successfully discharged and the rate of activities of daily life (ADL) improvement among short-stay residents.

SNF Updates 11 CMS added six new quality measures to Nursing Home Compare 1.Percentage of short-stay residents who were successfully discharged to the community (Medicare claims- and MDS-based) 2.Percentage of short-stay residents who have had an outpatient emergency department visit (Medicare claims- and MDS-based) 3.Percentage of short-stay residents who were re-hospitalized after a nursing home admission (Medicare claims- and MDS-based) 4.Percentage of short-stay residents who made improvements in function (MDS-based) 5.Percentage of long-stay residents whose ability to move independently worsened (MDS-based) 6.Percentage of long-stay residents who received an antianxiety or hypnotic medication (MDS-based)

SNF Updates 12 SNF Quality Reporting Program (QRP) The IMPACT Act, enacted on October 6, 2014, requires the implementation of a quality reporting program for SNFs beginning with FY 2018 SNFs that do not submit required quality data to CMS under the SNF Quality Reporting Program (QRP) will be subject to a 2.0 percentage point reduction to their annual updates CMS is proposing one new assessment-based quality measure, and three claims-based measures for inclusion in the SNF QRP. These measures align with the measures proposed for inclusion in the Long Term Care Hospitals (LTCH) QRP and the Inpatient Rehabilitation (IRF) QRP

SNF Updates 13 Assessment-based measure for the FY 2020 payment determination and subsequent years: Drug Regimen Review conducted with follow-up for identified issues. Claims-based measures for the FY 2018 payment determination and subsequent years: Discharge to Community – Post Acute Care (PAC) SNF QRP Medicare Spending Per Beneficiary (MSPB) – PAC SNF QRP Potentially Preventable 30 Day Post-Discharge Readmission Measure for SNFs The IMPACT Act requires that procedures for public reporting of quality and resource use and other measures include a process consistent with the Hospital Inpatient Quality Reporting (IQR) review and correction processes. CMS proposes the following for public display of quality measure data for the SNF QRP, including review and correction periods, and the pre- and public reporting preview period:

SNF Updates 14 Assessment-based measure for the FY 2020 payment determination and subsequent years: CMS proposes the following for public display of quality measure data for the SNF QRP, including review and correction periods, and the pre- and public reporting preview period: Align the SNF QRP quarterly reporting timeframes and quarterly review and correction periods for assessment-based measures with the approach followed in the IQR Align processes related to the review and correction of claims based measures with the approach followed in the IQR Apply a 30-day preview period prior to publishing SNF quality data during which corrections to data cannot be made, but SNFs may ask for a correction to their measure calculations.

SNF Updates 15 SNF Value-Based Purchasing Program (VBP) Section 215 of the Protecting Access to Medicare Act of 2014 (PAMA) added new subsections (g) and (h) to section 1888 of the Social Security Act The new section 1888(h) of the Social Security Act authorizes the establishment of a Skilled Nursing Facility Value-Based Purchasing (SNF VBP) Program beginning with FY 2019 under which value-based incentive payments are made to SNFs based on performance. This rule proposes to specify the SNF 30-Day Potentially Preventable Readmission Measure, (SNFPPR), as the all-cause, all-condition risk- adjusted potentially preventable hospital readmission measure to meet the requirements of section 1888(g)(2) of the Social Security Act. The SNFPPR assesses the facility-level risk-standardized rate of unplanned, potentially preventable hospital readmissions for SNF patients within 30 days of discharge from a prior admission to a hospital paid under the Inpatient Prospective Payment System, a critical access hospital, or a psychiatric hospital.

SNF Updates 16 SNF Value-Based Purchasing Program (VBP) In this proposed rule, CMS is seeking public comments on additional proposals related to the SNF VBP requirements including: Establishing performance standards Establishing baseline and performance periods Adopting a performance scoring methodology Developing confidential feedback report Patient Satisfaction will also be measured

SNF Updates 17 Changes to Payment Rates under the SNF Prospective Payment System (PPS) Based on proposed changes contained within this proposed rule, CMS projects that aggregate payments to SNFs will increase in FY 2017 by $800 million, or 2.1 percent, from payments in FY This estimated increase is attributable to a 2.6 percent market basket increase reduced by 0.5 percentage points, in accordance with the multifactor productivity adjustment required by law.

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Contact Us Kerry Dunning Chief Senior Services Officer