On Friday, December 4, the Centers for Medicare and Medicaid Services issued a memo on its intentions to update the Survey and Quality domains of Five-Star with the January 27, 2021 refresh of Nursing Home Compare data.
After January's update, all three Five-Star domains (Survey, Staffing, and Quality) will operate and update as they did prior to the COVID-19 pandemic. This includes updating which skilled nursing facilities have a Special Focus Facility designation and the Abuse and Neglect Icon. CMS previously unfroze the Staffing domain with the October 28, 2020 update.
Infection Control Focused Surveys to Be Counted as Complaint Surveys
The survey score used to determine a facility's Survey rating will reflect findings from infection control focused surveys.These surveys were prioritized for most of 2020 over standard health surveys.
For survey scoring purposes, deficiencies found during infection control surveys will be treated as complaint deficiencies.This means they will count more towards a survey score and rating during the immediate 12 months following the deficiency citation before gradually tapering off. For example, a G-level deficiency found during an infection control focused survey in April 2020 will most heavily be weighted until April 2021's Nursing Home Compare update. After that point, the weighting will be lessened as the deficiency will be considered a Cycle 2 deficiency. For more on survey cycles and deficiency weighting, see the Five-Star Technical Manual.
CMS understands states differ in their resuming of standard surveys and may be pausing standard surveys again due to rising COVID cases in the community and facilities. Because Survey ratings reflect performance within one state, CMS does not believe the difference between states on resuming surveys should hold up updating Five-Star ratings.
Quality Measures Will Reflect Performance Up to June 2020
CMS currently has not released data on quality measure rates past December 2019 (Q4 2019). With January 27's refresh of Nursing Home Compare data, CMS will update measures through June 2020 (Q2 2020). This means the latest 4-quarter measure rates used to determine Quality ratings will reflect performance from July 2019 (Q3 2019) through June 2020 (Q2 2020), including the first quarter of 2020.
CMS has analyzed the MDS assessments submitted during the COVID-19 pandemic and sees no issues in updating the measures to reflect Q1 and Q2 2020 data. They will continue to monitor the data and if necessary, adjust future measure updates.
This unfreezing of quality measures for Five-Star does not apply to the SNF Quality Reporting Program (QRP) measures currently. SNF QRP measures are currently scheduled to be frozen till January 2022, but that may change.
Facilities are encouraged to monitor and review their MDS 3.0 Quality Measure reports in the CASPER system to identify key areas for them to address during these challenging times.
The Impact of These Updates is Unknown
Like prior Five-Star Rating updates, there will be some facilities who see their ratings improve and others who see their ratings decrease on January 27. Some facilities will no longer be a Special Focused Facility Candidate or will no longer have the Abuse Icon on Nursing Home Compare. AHCA will analyze and share the impact of these changes as more data becomes available. CMS plans to update the Five-Star technical manual by January 15, 2021 with more specific information about the unfreezing of Five-Star. AHCA will develop and update a Frequently Asked Questions (FAQ) resource as we learn more.
Please contact Research@ahca.org if you have any questions in the meantime.