Provider Associations Meet with Region V
On December 15th and 16th of 2015, Rebecca Bartle (representing HOPE) and Kathy Johnson (representing LeadingAge Indiana) attended the annual Region V Provider Association Meeting in Chicago. This meeting is held with the purpose of allowing the state associations to convene in an effort to pose questions of industry interest to CMS, as well as be updated by CMS as to developments and initiatives.
Areas/topics of discussion which would be of particular interest to member facilities would include the following:
- Data trends as to commonly cited F-tags, LSC citations, etc. were presented and discussed. This information has been provided.
- The approximate 9,000 comments submitted on the draft “new rules” to govern facility certification are “under review.” A definitive date of the next release was not provided, however there was indication that providers should expect a release in 2016.
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CMS is still in the process of analyzing findings from the initial round of MDS Focus Surveys. Clearly, F278 was the most frequently cited tag.
- The Special Focus Surveys will not be considered or logged as “complaint” surveys in the future. They will be used in the Five Star calculation, in addition to the recertification surveys.
- CMS initiatives for 2016 include additional items in the MDS (10/1/16).
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CMS strongly encouraged providers to voluntarily participate in Payroll Based Journal (PBJ) reporting. The voluntary period began October 2015 and will extend through June 2016, becoming mandatory for all providers July of 2016 (to be reported quarterly within 45 days after the end of the quarter. Thus, first deadline should be 11/15- with data from July, August and September). Providers were encouraged to participate now at “no risk.” This will be mandatory and CMS can impose enforcement actions due to provider noncompliance
- Various questions were posed by providers relative to the categorization of “universal workers.” Providers were advised to the assign a universal worker to the category of his/her primary function. It was stated there should be a reasonable methodology as to allocation for contractors.
- There will be auditing for accuracy, however, CMS did not disclose how such auditing will be conducted, or at what frequency.
- Regarding full QIS implementation, it was reported further implementation in states not already utilizing QIS is “on hold.” CMS is working on a unified survey process (combining elements of the Traditional Survey Process with the Quality Indicator Survey Process).
- The previously released “abuse” memo was discussed and it was stated, CMS cannot comment, however, it has not been forgotten.
- Adoption of the 2012 Life Safety Code is still “in process.”
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Review of the Federal LSC process was explained as follows:
- There are six states in Region V. Five percent of surveys per year are conducted as “companion surveys.”
- The Federal surveyors identify state surveys to be conducted within the next 10-60 days.
- The Federal surveyors attempt to conduct and even distribution of LSC surveyors followed (which requires going to various regions of the state).
- They generally do no return to a facility for three years after having conducted a Federal companion LSC survey.
- The Federal LSC surveyors usually do not visit a Special Focus Facility.
- Concerted time was spent in discussion of “citation consistency.” Basically, whether surveyors consistently apply the scope and severity grid to deficient practices cited. The area of “falls” was discussed. CMS encouraged provider associations to submit concerns of inconsistent practice in citations and/or scope and severity assignment, as CMS has utilized consistency workgroups in the past, and is willing to continue said practice in the future.
Other information from the Region V meeting:
- Total Deficiencies Cited by Region V States and Nation by Severity Level on Standard and Complaint Surveys FY 2015
- Average Number of Deficiencies Cited Per Survey by Region V States and Nation on Standard and Complaint Surveys FY 2015
- Top 10 Citations Cited by Region V States and Nation on Standard and Complaint Surveys FY 2015
- List of Top Citations on Top 10 Report for Region V and Nation on Standard and Complaint Surveys FY 2015
- 2015 Top Ten Cited LSC Deficiencies SNF-NF
- Percentage of Harm Citations in Standard Surveys
- Top Ten Deficiencies and Helpful Hints to Avoid Them
- Remedies in Effect Region V States and Nation FY 2015
CoreMMIS and Portal “Go-Live” Date Postponed
The “go-live” date for implementation of the new Core Medicaid Management Information System (CoreMMIS) and Provider Healthcare Portal (Portal), originally slated for December 28, 2015, has been postponed. To ensure that Indiana Family and Social Services Administration (FSSA) standards for performance and quality are met, the new system is now expected to be available in 2016.
Indiana Health Coverage Programs (IHCP) providers, contractors and other stakeholders will receive as much advance notice of the new implementation date as possible. At least 30 days’ notice will be given regarding transition and conversion activities that directly affect providers and their ability to conduct IHCP business. The time frames associated with the suspension of accepting business transactions for processing in the current system are estimated as follows:
- Provider enrollments/profile updates – approximately 45 days prior to implementation
- Fee-for-service (FFS) paper claims/adjustments – approximately 30 days prior to implementation
- FFS electronic claims with attachments – approximately 30 days prior to implementation
- FFS electronic adjustments – approximately 15 days prior to implementation =
- FFS electronic claims without attachments – approximately 5 days prior to implementation
- FFS financial cycle (remittance advices, electronic fund transfers, checks) – normal schedule week prior to implementation; first financial cycle in the new system will run approximately one week after implementation
Details about these and any other necessary transition periods will be provided in upcoming IHCP publications. Providers should continue preparing for the new system. Related guidance will continue to be published in IHCP bulletins. Self-directed web-based Portal training is now available at indianamedicaid.com, allowing providers to become familiar with Portal features at their convenience. The Provider Relations Field Consultants will also schedule virtual trainings and on-site workshops in the coming months. Providers can help ensure they do not miss important information by signing up to receive IHCP email notifications.
HOPE Participating in the Nursing Facility/Hospital Collaborative
The Nursing Facility/Hospital Collaborative was formed in response to Medicaid proposal to use a portion of the IGT/UPL dollars to support closure of nursing facilities. The group consists of the Indiana Hospital Association (IHA), HOPE, LeadingAge Indiana, and IHCA. HOPE’s representatives include Mark Mutz, Mulberry Health and Retirement Center and Tom O’Niones, Transcendent Healthcare. The collaborative is co-chaired by Shelley Rauch from Westminster Village North and Jack Horner from Major Hospital.
The goals and objectives of the group are to:
- Better coordinate communications and dialogue between the NSGO hospitals and nursing facility managers/operators;
- Maintain the supplemental payment program which brings much needed resources to Indiana county hospitals and nursing facilities in order to serve Medicaid residents;
- Evaluate and develop positions on any proposed changes in the distribution and use of supplemental payments; and
- Develop consistent messaging regarding the benefits of long term care and hospital partnerships, including supplemental payments, for improving patient care and quality of life in Indiana.
The group also created three sub-committees focused on specific issues—financing, quality/benchmarking, and communications. The sub-committees will be comprised of interested members of the Collaborative, and will likely meet in person on a regular basis.
Update on Indiana’s 5-8 Year Rebalancing Plan
HOPE, LeadingAge Indiana, and IHCA met with Joe Moser, Medicaid Director, Yonda Synder, Aging Director, and Myers & Stauffer staff on November 30 to discuss next steps in the state’s 5-8 year rebalancing plan. This was the first step in developing an agreement between the state and the nursing home industry on a variety of issues.
The following items are up for discussion in developing this agreement:
- Whether Medicaid managed care for the dually eligible population will be implemented: HOPE strongly opposes this.
- Nursing home capacity reduction: This would involve identify a source of funding to incentivize closures. HOPE opposed use of the IGT/UPL supplemental dollars proposed by Medicaid.
- Whether there should be incentive/disincentives for the nursing home industry of state targets for rebalancing aren’t achieved. The state laid out their targets which would move the split of funding for institutional versus home and community based services from the current level of 67%/33% to 55%/45% by 2023. Click here to see these targets.
- Support for extension of the moratorium in 2017. HOPE strongly supports this extension.
- Increasing the amount of quality assessment assessed to draw down additional federal dollars and if these would be used to incentivize facility closures, expand funding for home and community based services, or other purposes.
- Whether a portion of the IGT/UPL should be allocated on the basis of a quality measure.
- Improvement and expansion of the state’s Medicaid Waiver program.
HOPE members will be kept up-to-date as these discussions continue.
Revision of Nurse Aide Training Curriculum
The Indiana State Department of Health Nurse Aide Curriculum provides the standards for training of Nurse Aides. The current curriculum became effective January 2014. Part of curriculum includes Resident Care Procedures (RCPs) which are the step by step instructions for specific procedures. The RCPs are demonstrated as part of the nurse aides training programs and are also utilized by facilities in in-service education and skill validations for certified nurse aides.
Practice for all healthcare workers is the proper sequence and procedure when using Personal Protective Equipment (PPE). The Centers for Disease Control and Prevention (CDC) issued information on the Sequence for Putting On / Removing PPE (http://image.exct.net/lib/ff011270716507/d/1/ppeposter8511.pdf) in an effort to clarify this important practice. A review of the Nurse Aide Curriculum RCPs revealed a need to revise "Procedure #5: Gown (PPE)" (http://image.exct.net/lib/ff011270716507/d/1/RCP-5.pdf).
All approved Nurse Aide Training Programs have been notified of this change which was effective November 19, 2015. All questions should be directed to Gina Berkshire, RN, Aide Education & Training Program Manager at 317-233-7497 or gberkshire@isdh.in.gov.
Money Follows the Person Changes
According to the Division of Aging, Money Follows the Person transition benchmarks have already been met and exceeded for 2015. This program pays a larger match when nursing home residents are moved to home- and community-based services. However, the state has not received approval from CMS for the 2016 MFP budget. They anticipate that they will have this approval in January.
Therefore, they have directed Carestar to not target any new individuals for transition through MFP. Any individuals targeted for transition and enrolled in MFP prior to November 23 will be allowed to complete the process, but no new enrollees will be allowed into MFP until they have more information about the 2016 budget.
This does not mean that they will not be allowing transitions during this time. Candidates for transition may still be referred to the Area Agencies on Aging for transition directly to the A&D waiver. They have asked Carestar to make these referrals to the AAAs. They simply will not have the MFP enhanced match for these transitions.
Correction Regarding Inappropriate Denials of Nursing Facility Claims for HIP Members
The Indiana Health Coverage Programs (IHCP) Banner Page BR201545 incorrectly stated that an eligibility issue caused nursing facility claims for Healthy Indiana Plan (HIP) members to deny inappropriately. The eligibility issue described in this publication related only to Hoosier Care Connect (HCC) member claims processed between April 1, 2015, and October 28, 2015. HIP member claims were not affected.
Summary of Indiana Residential Survey Tag Report
The most frequently cited residential tags for November 2015.
Definitions of Indiana Residential Tag classifications:
Offense: Substantial probability that death or a life –threatening condition will result. Requires immediate correction.
Deficiency: Immediate or direct, serious adverse effect on the health, safety, security, rights, or welfare of a resident.
Noncompliance: In-direct threat on health, safety, security, or rights of a resident.
For the month of November 2015 the cited Offenses were:
| Tag Cited | # of Facilities Cited | Category | Description |
|---|---|---|---|
| R0052 | 2 | Residents’ Rights-Offense | Residents have the right to be free from: Sexual abuse, physical abuse, mental abuse, corporal punishment, neglect, and involuntary seclusion. |
| R0241 | 6 | Health Services- Offense | The administration of medications shall be ordered by the resident’s physician and shall be supervised by a licensed nurse on premises or on call. Medication shall be administered by licensed nursing personnel or qualified medication aides |
| R0242 | 1 | Health Services - Offense | The resident shall be observed for effects of medications. Documentation of any undesirable effects shall be contained in the clinical record. The physician shall be notified immediately if undesirable effects occur, and such notification shall be documented in the clinical record. |
Frequently Cited Deficiencies in November 2015:
| Tag Cited | # of Facilities Cited | Category | Description |
|---|---|---|---|
| R0090 | 3 | Administration and Management-Deficiency | The administrator is responsible for the overall management of the facility. Responsibilities include: 1. Informing the division within 24 hours of unusual occurrence that directly threatens the welfare, safety, or health of a resident. |
| R0144 | 2 | Sanitation and Safety Standards-Deficiency | The facility shall be clean, orderly, and in a state of good repair, both inside and out, and shall provide reasonable comfort for all residents. |
| R0217 | 2 | Evaluation-Deficiency | Completion of an evaluation, the facility using appropriately trained staff members, shall identify and document the services to be provided by the facility. |
| R0243 | 2 | Health Services-Deficiency | The individual administering the medications shall document the administration in the individual’s medication and treatment records that indicate the: time, name of medication or treatment, dosage, and Name or initials of person administering the drug or treatment. |
| R0273 | 9 | Food and Nutritional Services-Deficiency | All food preparation and serving areas are maintained in accordance with state and local sanitation ,including 410 IAC 7-24 |
The following Tags were cited at least once at a deficiency level in the Month of November 2015: R0036, R0044. R0053, R0055, R0154, R0214, R0240, R0246 and R0414.
Number of Offense Tags cited: 9
Number of Deficiency Tags cited: 27
Number of Residential Tags cited: 36
Bed Census Reporting
In accordance with the 2015 Senate Enrolled Act 460, all comprehensive and resident care facilities are required to report their actual bed census on January 1 and July 1 of each year. The bed census data is used to determine occupancy rates for each county in determining eligibility for licensure. This data is also important for disaster preparedness in being able to quickly identify counties and facilities with available beds.
In July 2015, the first reporting period, ISDH established an online process for reporting the bed census data. The January 1 reporting will be through the online ISDH Gateway System (https://gatewayp.isdh.in.gov/Gateway/SignIn.aspx). This is the same system used for obtaining survey reports and reporting incidents.
The bed census is intended to include all licensed beds, both comprehensive and residential, in the facility including special units such as Alzheimer's/Dementia or ventilator unit. The ISDH must obtain census information from every facility. The facility's census on January 1 should be submitted to the ISDH by January 15, 2016. Once the ISDH has the January 1 data for all facilities a bed occupancy report will be published.
Since the last reporting in July some changes have been made to the Bed Census & Personnel Tracking section of the online ISDH Gateway System. The Instructions for Bed Census Tracking Process and Bed Census Reporting Frequently Asked Questions are available to assist with submission.
Medicaid Clarifies the Nursing Facility Special Care Unit Calculation
Indiana Health Coverage Programs (IHCP) nursing facilities with special care units (SCUs) are eligible for increased reimbursement in the form of an SCU add-on to their Medicaid rate. Medicaid recently provided a clarification on this calculation that can be see here: http://provider.indianamedicaid.com/ihcp/Bulletins/BT201582.pdf