The Centers for Medicare & Medicaid Services (CMS) just released the 2012 Nursing Home Action Plan; a guide for CMS’ efforts to continue to improve nursing home safety and quality. The plan features 5 actionable strategies, including: enhance consumer engagement; strengthen survey processes, standards, and enforcement; promote quality improvement; create strategic approaches through partnerships; and advance quality through innovation and demonstration.
The five actionable strategies are based on CMS’ Three-Part Aim for improving health care in the U.S.:
1) improve the individual experience of care;
2) improve the health of populations; and
3) reduce the per capita cost of care for populations.
Each strategy is executed with the goal of furthering the progress of the Three-Part Aim to improve nursing home safety and quality.
Enhance Consumer Awareness and Assistance
CMS seeks to provide an increasing array of understandable information about nursing homes that can be easily accessed by the public. Part of this enhanced consumer awareness is the updates to the Nursing Home Compare website, set to launch later this month.
The updates to the Nursing Home Compare website include new MDS 3.0 qaulity measures, the up-coming redesign of the website, ongoing evaluations of additional quality measures to include on the website, and disclosure of nursing home ownership information. Within the 2012 Action Plan, one of the next developments for the Nursing Home Compare website is the development of a prototype system to collect payroll-based staffing data, an initiative set for Spring 2013.
Strengthen Survey Process, Standards, and Enforcement
CMS is engaged in several ongoing initiatives to improve the effectiveness of annual nursing home surveys, as well as the investigations that are prompted by complaints from consumers or family members about nursing homes.
CMS aims to improve fire safety in nursing homes by focusing on better protection, information and reporting, monitoring, and enforcement. These fire safety improvements will be implemented in Life Safety Code (LSC) surveys.
CMS will continue to revise the State Operations Manual (SOM), including the Interpretive Guidance to Surveyors for Long Term Care Facilities for regulatory requirements. The revisions will take advantage of an interactive process using expert panels and comment periods. Specifically addressed in the Action Plan are upcoming revisions to guidance related to feeding tube tags and end of life and advanced directive tags, expected this summer.
CMS is expected to release draft guidance on the Independent IDR process and the process for CMS to approve the use of CMPs in development this winter. Additionally this winter, CMS is going to conduct data analysis on the frequency and amounts of CMPs to determine trends and outliers to improve consistency.
Promote Quality Improvement
CMS promotes a system-based, comprehensive program of quality improvement as well as improvement in a number of specific areas. These specific areas include the reduction in the incidence of preventable pressure sores, reduce injurious falls, and the reduction in the extent to which physical restraints are used in nursing homes.
The implementation and ongoing maintenance of MDS 3.0 will continue to be a focus of CMS. Revisions to the Long-Term Care Facility Resident Assement Instrument (RAI) User’s Manual will be issued in April and October 2013, along with updates to Quality Measures and RAI Coordinators’ Training in March 2013. Quality Measure survey products and the integration of new Quality Measure Reports into the traditional survey process will occur during the summer and fall of 2013.
Culture Change remains an ongoing issue for CMS, as facilities are encouraged to provide individualized care that best enhances each person’s quality of life. Part of this ongoing initiative is to adopt the 2012 Life Safety Code, study State government programs to enhance Medicaid payments to nursing homes implementing culture change, and revise interview questions on survey forms to account for the Quality of Life tags.
The Quality Assurance and Performance Improvement (QAPI) initiative has just started implementation in full force. The Nursing Home Quality Improvement Questionnaire has already been sent out to providers. Expect a report from the 17 volunteer nursing homes who participated in a demonstration QAPI project, as well as a proposed QAPI rule in 2013.
Another significant focus for CMS is the use of antipsychotics in nursing facilities. Stemming from a report to Congress last fall, CMS has remained focused on reducing the amount of antipsychotics utilized in nursing facilities. (See here, here, here, and here). Not only will antipsychotic use be included on the Nursing Home Compare website starting mid-July, CMS will also be training surveyors, providers, and prescribers on the over use of antipsychotic medications beginning this summer through 2013.
Create Strategic Approaches Through Partnerships
CMS states effective quality assurance in nursing homes is best achieved through the combined, motivated, and coordinated approach by many stakeholders in the health care system, including:
- Consumers, their families, and friends
- Providers
- Purchasers
- Professionals
- Survey and Certification agencies
- Quality Improvement Organizations
- Universities and other educational and research organizations
- Legal rights organizations, including advocacy groups such as the AARP
CMS’ goal is to promote quality care by an increasing number of entities in the health care system acting synergistically. CMS will encourage collaboration among individuals and organizations that are responsible for ensuring quality.
Advancing Quality Through Innovation and Demonstration
CMS’ demonstration projects foster health care transformation by finding new ways to pay for and deliver care that improve care and health while lowering costs. These projects include Medicare’s current Nursing Home Value-Based Purchasing (NHVBP) Demonstration, which aims to promote high-quality care and prevent costly, potentially avoidable hospitalizations and develop plans to implement VBP programs for payments under the Medicare program for both Skilled Nursing Facilities (SNFs) and Home Health Agencies (HHAs).
The Initiative to Reduce Avoidable Hospitalizations among Nursing Facility Residents was developed jointly by the CMS’ Center for Medicare and Medicaid Innovation (Innovation Center) and the Medicare-Medicaid Coordination Office (MMCO). Through this initiative, CMS will partner with organizations to implement evidence-based interventions that reduce avoidable hospitalizations. These organizations will collaborate with States and nursing facilities, with each enhanced care and coordination provider implementing its intervention in at least 15 partnering nursing facilities.
Should you have any questions, please contact:
Todd Selby at 317.977.1440 or tselby@wp.hallrender.com;
Brian Jent at 317.977.1402 or bjent@wp.hallrender.com; or
David Bufford at 502.568.9368 or dbufford@wp.hallrender.com,
or your regular Hall Render attorney.
