12/11/2019

Act Now: Some NFs to be Excluded from Quality Payment

In mid-July, the Ohio General Assembly passed a bill that would boost payments to Ohio nursing homes by 2.4 percent in January 2020 via a quality incentive payment, and by an estimated 5 percent in July 2020. A less-discussed provision of the bill would exclude certain lower-occupancy nursing homes from the increases beginning on July. Nursing homes can take action between now and December 31 to ensure they receive the quality incentive payment (QIP). 

Beginning on July 1, 2020 nursing homes that are under 80% occupancy for 2019 and have fewer than 15 quality points based on the four measures identified in the quality incentive program, will be excluded entirely from receiving the quality incentive payment (QIP).

• Occupancy will be calculated based on the days reported on cost reports, and the number of licensed beds as of December 31, 2019. This means that nursing homes that are at-risk of losing their QIP because of low occupancy could choose to relinquish beds to ensure they will be able to receive the QIP.  This is a permanent surrender of bed licenses.
• The quality incentive payment amount will represent at least a 2.4% increase to reimbursement over FY 2019 levels. If the legislature approves the anticipated budget correction bill language, this amount could be an estimated 5% over FY19 payment levels. However, this increase is distributed unevenly with some providers receiving no increase and others receiving increases much higher than 5%.

LeadingAge Ohio has been reviewing available data to identify members who are at-risk of being excluded from the QIP based on occupancy levels and quality points, and reaching out to them directly. However, the data being used by LeadingAge Ohio is different than the data that will be used by ODM, so LeadingAge Ohio encourages members to undertake their own reviews to determine whether they will be eligible for the quality incentive payment. 

Ultimately, ODM plans to use census data found on the cost report from four quarters in 2019, as well as CMS data for the four measures over the four quarters of 2019, to determine who would be excluded from the payment.  It is important to note that while occupancy is being used as a “qualifier” to receive quality points for FY20, going forward the future of the quality program would be part of the upcoming biennium budget negotiations.

To that end, we recommend members take a look at the following data points, to determine their risk for being excluded from the QIP:

• Calculate 2019 occupancy.
• Estimate the total number of days across categories, as collected in the nursing facility cost report.
• Divide total days number by the total number of licensed beds.
• If this number is 80% or above, your nursing facility will not be excluded from the QIP, so no need to do further calculations.
• If it is below 80%, look at your 2019 performance on four quality measures (catheter lines, UTI, wounds & decreased mobility)
• To calculate your quality points, reference the thresholds outlined in the CMS Five Star Technical User Guide, beginning in the Appendix on page 21.
• If performance falls into the lowest category for a measure, assign zero (0) points for that measure. For any other category, assign the number of points noted in the Technical User Guide tables.
• Find the sum of points for four measures, then divide it by 20. If this number is equal to or greater than 15, your nursing facility will not be excluded from the QIP. 

If occupancy rate is below 80% and quality points are below 15, you are at risk for losing the quality incentive payment. We encourage you to reach out to your accountant/controller, who will be able to gauge whether the potential additional payments available via the QIP would warrant relinquishing beds. ODM will be calculating the number of licensed beds as of December 31, 2019, so if your nursing facility stands to lose a great deal of reimbursement, relinquishing beds to bring occupancy above 80% may be a sound decision.  

Plante Moran has shared a helpful fact sheet to assist members in navigating the quality incentive payment.  

LeadingAge Ohio encourages members who are concerned about this to reach out directly to Susan Wallace, Director of Government Relations and Public Affairs by emailing swallace@leadingageohio.org or calling (614) 545-9024.