Questions about a change of ownership (CHOW) are common among Texas nursing facilities. One of the most confusing aspects can be how to properly handle PASRR Level 1 Screening Form (PL1) updates for individual residents.
Our friends at Texas Medicaid Coalition recently contacted the Texas Department of Aging and Disability Services (DADS) to confirm the steps a nursing facility must follow during a CHOW.
The process as it stands now is labor-intensive, requiring the nursing facility (NF) to enter a new PL1 for every resident within 90 days of the new Medicaid contract number being assigned. But there’s good news: DADS is currently working on changes to the process and the future plan is to have an option of the receiving NF being able to accept the PL1s already in the system from the sending NF.
Until the new procedure is implemented, here is the current process for managing PL1s during a CHOW (as confirmed by DADS):
Steps for implementing PASRR in CHOW
- Notify DADS PASRR unit via email that the facility is going through a CHOW. Provide the following information:
- Former NF name
- Former NF address
- Former NF vendor/contract number
- New NF name
- Date CHOW process was initiated
- Total number of current residents
- The NF must enter a PL1 for every resident, regardless of payor, once TMHP LTC portal access is reinstated and the new contract number has been assigned,
- The NF has 90 days to enter all PL1s after the new contract number was assigned.
- DADS asks that NFs stagger their PL1 submissions, limiting positive PL1 entries to only three to four per week. This allows the Local Authority (LA) time to manage their PASRR Evaluation (PE) workload. NFs may enter as many negative PL1s as they need to.
- The current (sending) NF completes the PL1 for the receiving NF, acting as the Referring Entity (RE). The NF can copy information from the old PL1 to use for the PL1 for the new contract number.
Common CHOW questions
During SimpleLTC’s highly attended PASRR webinar in June, we received 200+ questions regarding PASRR and the CHOW process. You can find the detailed answers on our PASRR resources page, but here are some of the top questions customers asked:
Do we have to submit a PL1 for all residents of facility (both pre-CHOW and post-CHOW)?
Yes. Because the TMHP system sees the old facility and the new facility as being separate, a new PL1 must be submitted for all residents present in the NF at the time of the CHOW as well as all residents admitted after the CHOW takes place.
After a CHOW, do we put the date of entry as the original entry date or the CHOW date?
The CHOW date is the date of entry because the resident is technically transferring from the old pre-CHOW facility to the new post-CHOW facility.
Why are NFs responsible for completing PL1s? Are they considered to be Referring Entities (RE)?
NFs are allowed to complete the PL1 in NF-to-NF transfers. In the case of a CHOW, the same nursing facility is both the sending and receiving nursing facility.
What is SimpleLTC doing to help?
As PASRR continues to evolve, SimpleLTC has implemented several enhancements to SimpleCFS to help you avoid PASRR compliance issues:
- All THMP-issued alerts will automatically appear within SimpleCFS.
- An admission LTCMI warning is displayed when submitting the LTCMI if the resident does not have a PL1 on file.
- A “Medicaid Residents Missing PL1” report identifies active residents (based on form history) who do not have a PL1 on file.