Recap of the CMS SNF/LTC Open Door Forum – August 6, 2020

Mary MadisonClient News, Skilled NursingLeave a Comment

You can find the agenda items for this Open Door Forum on my blog earlier this week.

CMS got started about 9 minutes late, but they had a lot to convey to providers/stakeholders.  Here’s a synopsis of what was covered (the links in this synopsis will point you to recent blogs and additional information):

  • The FY2021 SNF PPS Final Rule was posted on July 31, 2020.  John Kane, CMS SNF Team Lead/Technical Advisor noted that there were some changes to FY 2021 PDPM ICD-10 Mappings in response to stakeholder comments.  All mapping changes came from stakeholders, John reported.
  • June 25, 2020 saw the end of the blanket waiver, including PBJ submission.  All LTC providers must submit their 2020 Q2 staffing data by August 14, 2020.  CMS is encouraging submission of 2020 Q1 staffing data (turns out a lot of folks did submit that – kudos to you!).  In short, submitting Q1 staffing data will not be used against you as far as Five-Star ratings but CMS would like to have that quarter’s data.   A new email address/mailbox was identified for PBJ questions.  That mailbox is identified on the agenda;   Additionally, CMS noted that NHs can report National Guard staffing hours during the PHE ONLY if the facility receives documentation from FEMA (Federal Emergency Management Agency) verifying that the National Guard provided staffing.
  • Ellen Berry of CMS (“old-timers” working with MDS will recognize Ellen’s name) noted that MDS 3.0 v1.17.2 will be implemented on October 1st of this year.  This update to the version we are currently using allows states to calculate PDPM for their Medicaid state case-mix reimbursement, specifically on OBRA assessments (NC and NQ).  The updates found in v1.17.2 will provide the grouper for that state case-mix calculation.  Individual states that utilize the MDS for case-mix purposes are working on their decision to use the updates found in Sections GG, Column 1 (this column, for both Self-Care and Mobility, will be used for PDPM/case-mix  reimbursement only on OBRA assessments; they will not be used for quality measures) with OBRA assessments or utilize the OSA (Optional State Assessment) provided by CMS previously.  CMS has asked these states to notify them of their decision by October 1st so the QIES system can be updated however an individual state can choose to use the OBRA assessments for case-mix calculation after that date.  Providers should be receiving their state’s decision shortly – if not they should contact their state for that information.  It was also noted that a State can make that decision after October 1st and notify CMS.

Additionally, it was reported that CMS is NOT going to issue a new RAI User’s Manual this year. Providers should continue to reference the October 1, 2019 RAI Manual.  John Kane offered that this version contains all the information needed for use with encoding v1.17.2 and that the instructions found on the MDS 3.0 Item Sets proper will indicate coding of GG0130, GG0170, I0020 and J2100.  Clinicians should always use the guidance provided in the RAI Manual when encoding I0020 and J2100.

I asked CMS during this call if they would be notifying their survey teams of the decision to not produce a new or updated RAI Manual to be used with v1.17.2.  CMS stated that they would make sure that the survey teams were informed of this.  As you know, surveyors often ask to see the RAI Manual a facility is using to be sure it’s the current version.  If not, a deficiency can be cited.  So, the short of this is keep using the October 2019 version of the RAI User’s Manual.  I will keep our readers/customers posted in the event that CMS does issue change pages in the future. That’s not in the cards right now.

  • I also asked when CMS will post the updated Appendix PP.  This is the State Operations Manual (SOM) Appendix that is commonly referred to as the RoP (Requirements of Participation).  CMS told providers last year that they were updating Appendix PP to include Phase 3 RoP guidance as well as needed clarifications and that this update would be available in 2nd quarter of 2020.  The answer was that CMS is still working on that update and that there currently is no date for its release.  Stay tuned for an update on that when I hear of one.

Thank you for all the care you provide to your residents!!  Don’t forget to take care of yourself and your staff.  Stay safe and healthy out there!

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