Therapy Management & Consulting Services Blog

2017 SNF Survival Guide

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Major changes are taking place this year for HealthPRO®/Heritage customers! Preparation is key. HealthPRO®/Heritage’s “SNF Survival Guide” outlines two of the most critical CMS actions, and sets the stage for strategic planning and execution on what skilled nursing clients can do to not only survive the battles but to ultimately win the war.

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Priority #1: Challenges of Today Become the Victories of Tomorrow

The new value-based, quality-focused reimbursement mandates are officially in play. As of January 1, 2017, all skilled nursing facilities nationwide are to be evaluated, ranked, and subsequently reimbursed, (or not) according rules outlined in the new Value Based Purchasing Program (“VBP Program”). This critical game-changing CMS initiative means that up to 90% of all fee-for-service payments will now be linked, as promised, to how well skilled nursing homes are able to deliver better clinical outcomes and an optimal care experience for Medicare beneficiaries.

Need-to-Know Facts: The VBP Program

Two percent of SNF payments will be withheld and then subsequently paid back in 2019 only to those who are able to proactively improve or achieve rehospitalization rates relative to their peers nationwide.

As of January 1, 2017, SNFs’ All Cause Readmission Rates (“SNFRM”) will be tracked; this is the “Performance Period.” The SNFRM estimates the risk-standardized rate of unexpected readmissions within 30 days for traditional Medicare beneficiaries who were inpatients in SNF's, critical access hospitals, or psychiatric facilities. Furthermore, the SNFRM is tracked for any cause or condition that is readmitted to the hospital, and not to the SNF, inclusive of:

  • A SNF admission occurring within 1 day after discharge from the prior hospital stay;
  • An unplanned hospital readmission for Medicare fee-for-service SNF patients within 30 days of discharge from a prior hospitalization.

NOTE: The SNFRM is adjusted to account for patient differences, such as comorbidities, when comparing facility readmission rates. SNFRM performance information will be made available to each SNF through confidential quarterly feedback reports.

The VBP Program encourages SNF providers to monitor and reduce hospital readmissions, thereby reducing costs and improving the quality of care for Medicare beneficiaries. Success will be measured, or scored by both achievement and improvement on the 30-Day All Cause Readmission Measure (or “SNFRM”). CMS will then force-rank all SNFs nationwide from low to high based on these scores.

  • Achievement Score: Points awarded by comparing the facility’s inverted rate in the performance period (CY 2017) to the performance of all facilities nationally during the Baseline Period (CY 2015)
  • Improvement Score: Points awarded by comparing the facility’s rate during the performance period (CY 2017) to its previous performance during the Baseline Period (CY 2015)

Priority #2:  “If you want peace, you must prepare for war”

Not since 1991 has the skilled nursing industry been witness to such significant and sweeping regulatory and practice changes from CMS. With dramatic impact for both post-acute and LTC patient settings, the CMS Final Rule will dictate major regulatory changes over three phases in areas such as:

  • the current survey process
  • the review of quality measures;
  • general policy and practice guidelines;
  • documentation practices;
  • as well as patient-centered care planning and discharge planning.

As of November 28, 2016, SNFs are subject to principles outlined in the first phase of The Final Rule, while Phase 2 implementation is scheduled to begin this year in November 2017.

Need-to-Know Facts: The Final Rule

Discharge planning is a major focus. As such, HealthPRO®/Heritage customers must execute on redesign initiatives to assure the following processes are in place.

  • Baseline care planning for each resident within 48 hours of admission will be required.
    • Supports safe transitions process for 48 hour meeting and aligns with most section GG communication
    • Requires patient/caregiver involvement including signature of engagement
    • Requires reformatting of all facility notification of transfer forms
  • For residents that will be transferred to other PAC providers, facilities must assist in the decision by providing integral outcome details such as, but not limited to:
    • Standardized patient assessment data
    • Quality measure information

Conventional wisdom suggests that while Phase 1 of The Final Rule may present challenges inherent in making important changes, Phase 2 will actually prove to be the most taxing for most SNF providers. It will require considerable training, resource allocation, and drastic changes in the current paradigm. Plan accordingly for Q4 2017 and beyond!

Please refer to the tables below for specifics related to the roll-out of Phases 1-3.

      Phase One
  • Resident rights and facility responsibilities
  • Freedom from abuse, neglect, and exploitation
  • Admission, transfer, and discharge
  • Resident assessment
  • Comprehensive, person-centered care planning
  • Quality of life
  • Quality of care
  • Physician services
  • Nursing services
  • Pharmacy services
  • Laboratory, radiology, and other diagnostic services
  • Dental services
  • Food and nutrition
  • Specialized rehabilitation
  • Administration (Facility assessment - Phase 2)
  • Quality assurance and performance improvement - QAA committee
  • Infection control program
  • Physical Environment

      Phase Two
  • Quality assurance and performance improvement - QAPI Plan
  • Infection Control - Facility assessment and antibiotic stewardship
  • Behavioral health services
  • Compliance and ethics
  • Physical environment - smoking policies

      Phase Three
  • Quality assurance and performance improvement - Implementation of QAPI
  • Infection control - infection control preventions
  • Compliance and ethics
  • Physical environment - call lights at resident bedside
  • Training


“Before Anything Else, Preparation is the Key to Success”

HealthPRO®/Heritage takes its role seriously in helping to ensure our clients not only survive, but thrive in 2017 and beyond. Regular education regarding the extent of these CMS changes (including deadlines and tips for success) is the foundation of our partnerships. Additionally, HealthPRO®/Heritage can support/implement clinical and operational initiatives to optimize discharge planning and documentation practices to align with CMS mandates. HealthPRO®/Heritage successfully assists SNF clients with critical care redesign initiatives (such as with re-hospitalization mitigation, medication management, data collection/scorecard, clinical niche programming, QAPI/QM programming, etc.) as well as therapy management services.

For more information on how HealthPRO®/Heritage can help, please contact the Clinical Strategies Division.

Tags: CMS, post acute care provider, CMS Update 2017, snf, HealthPRO/Heritage, value based purchasing program, post acute, LTC provider, snf survival guide, vbn program, all cause readmission rates, SNFRM, LTC, Advisor