Significant Minimum Data Set (MDS) 3.0 assessment changes effective October 1, 2023 will impact Five-Star reporting for both the Quality Measure (QM) rating and the Staffing rating. CMS communicated the details of these changes in memo QSO-23-21-NH dated September 20, 2023. This memo also addresses changes to CMS forms 671 (Long-Term Care Facility Application for Medicare and Medicaid) and 672 (Resident Census and Conditions of Residents) due to the MDS item changes.
CMS will no longer support the RUG-III and RUG-IV payment methodology on federally required assessments as of October 1, 2023 by removing many MDS items required to calculate these scores. The removal of section G used to calculate the activities of daily living (ADL) score for all RUG scores will especially impact the QM rating and the Staffing rating reported on the Care Compare website, as well as on Five-Star reports.
Impacts to the Five-Star Staffing Rating
Providers use the Payroll-Based Journal (PBJ) system to report actual staffing levels to CMS. These reported staffing levels are case-mix adjusted for acuity prior to calculating the staffing rating points assigned for RN Staffing, Total Nurse Staffing, and Total Nurse Staffing on the Weekend.
Prior to the October 1, 2023 MDS update, the reported staffing levels were case-mix adjusted using a calculation based on the RUG-IV 66 grouper. Since the RUG-IV grouper is no longer supported by CMS, a similar methodology based on the daily distribution of residents by Patient-Driven Payment Model (PDPM) Nursing Case-Mix Group (CMG) has been developed. In addition, revisions to the staffing rating thresholds based on PDPM are planned so that the distribution of points will not change.
During the case-mix adjustment transition period from RUG-IV to PDPM, CMS will freeze the staffing measures during a three-month period beginning in April 2024 before resuming reporting in July 2024.
While MDS updates are not impacting the turnover staffing rating points, CMS is concurrently revising the turnover measures to apply a penalty for missed or inaccurate submissions of PBJ data instead of excluding the measures from the calculation of the staffing rating. Specifically, CMS will apply the lowest point level possible to all turnover measures instead of excluding the measures from the calculation of the staffing rating. The RN and Total Staff Turnover measures each have a minimum point value of 5 and the Administrator Turnover measure has a minimum point value of 10.
Impacts to the Five-Star QM Rating
With the removal of section G from the MDS, one short-stay QM is being replaced and three long-stay QMs will need to transition to section GG to calculate the measure.
The Residents Who Made Improvements in Functions short-stay measure will be replaced with the Discharge Function Score measure.
The Residents Who Made Improvements in Functions QM will be frozen on the Five-Star reporting starting in January 2024. Reporting on the new Discharge Function Score QM will begin in October 2024.
Residents Whose Need for Help with ADLs Has Increased QM and Residents Whose Ability to Move Independently Worsened QM will each be reformatted to replace section G data with equivalent section GG data.
High-Risk Residents with Pressure Ulcers QM will be replaced with the similar Residents with Pressure Ulcers QM, removing the high-risk consideration from the measure.
These three long-stay QMs will be frozen on the Five-Star reporting staring in January 2024. Reporting on similar measures using section GG data will resume in January 2025 when data for the revised measures has been collected.
Additional details regarding measure specifications for these four QMs and the impact to the Five-Star Rating can be found in the following links:
- Nursing Home Five-Star Quality Rating System: Technical Users’ Guide September 2023
- MDS 3.0 QM User’s Manual v.16.0
- SNF Quality Reporting Program Measure Calculations and Reporting User’s Manual v.5
CMS Survey Forms
Prior to October 1, 2023, CMS-672 completed for survey purposes used section G to complete several fields on the form. Beginning September 29, 2023, providers will no longer complete any field where section G data is required.
The remainder of the form addressing census data, ombudsman information, and medication error rates will still be completed until October 22, 2023, when these fields will be moved to CMS-671. CMS-672 will then be discontinued.
If you have any questions or need assistance, please reach out to a professional at FORVIS.