Medicare Advantage Grabs Spotlight in CMS, Nursing Home Operator Discussion on MDS Requirements

It appears the Centers for Medicare & Medicaid Services (CMS) is paying particular attention to managed care payers as the agency re-examines data submission requirements for skilled nursing services through the Minimum Data Set (MDS).

Nursing home operators were able to comment on various MDS-related questions posed by CMS officials during a Quality Reporting Program (QRP) listening session held on Tuesday, with a focus on expanding MDS data submission to all SNF patients, regardless of payer.

Notably, the agency is asking for feedback from the industry on any burdens associated with data collection and submission on all patients.

“I think the biggest burden to consider is the end of [Prospective Payment System] PPS stay assessments that we do not already complete for managed Medicare,” one commenter said.

Another added that some payers have separate assessment tools that may be required to fill out, mainly around therapy services. It was unclear if this was in regard to managed care plans.

Coupled with administrative burden, the agency sought commentary on how the current definition of skilled nursing and rehabilitation services across multiple care settings is affecting MDS assessments.

The MDS definition states, “Skilled nursing services or skilled rehabilitation services, or a combination of those, must be needed and provided on a daily basis. That is, a seven day a week basis. A patient whose inpatient stay is based solely on the need for skilled rehabilitation services would meet that daily basis requirement when they need and receive those services at least five days a week,” said Elena Strunk, clinical lead with policy research company Acumen.

The definition goes on to say the definition shouldn’t be applied so strictly if there’s an isolated break in services for a day or two, Strunk added.

“We think that this definition might potentially provide some alignment between payers, especially between Medicare fee-for-service and Medicare Advantage beneficiaries, since all Medicare Advantage plans must use a similar definition, at least in relation to short stay residents,” she said.

Operators on the line said they’ve run into problems with MA programs when it comes to SNF stay definitions. Some plans are cutting off service coverage at 14 days, with SNF operators left asking MA plans what exactly their definition of skilled services is as a result.

Many MA plans don’t even require MDS documentation, while others do, with operators sometimes left to create a Merit-Based Incentive Payment System (MIPs) code to bill by, another commenter said.

Multiple commenters suggested CMS streamline whether or not MA plans should require MDS documentation.

Another area for feedback – should CMS reconsider how it collects and displays payer information through MDS to ensure greater accuracy and transparency.

CMS also asked for clarification on who in the SNF is primarily filling out this information on the MDS, and if there are any suggestions for how CMS can ensure such data is accurate.

“Adding an item to identify the payer is relevant and could be useful, but maybe you could consider excluding MA plans that initiated the cut in services with an MDS item – something that could indicate that they were the ones making the decision versus the facility, or patient,” one commenter said.

A last area of questioning dealt with changes in levels of care, a unique situation for SNFs, CMS representatives said. Specifically, the agency asked what kinds of changes in service level or level of care should be considered in an all-care policy, and if it would be beneficial to have payer source and qualitative data reported by residents.

One commenter said changes in service level should be limited to short-term services, since QRP reporting is intended to just address these types of patients.

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