Friday, June 26, 2020

CMS Memo Confirms PBJ Submission Deadline and Provides Five-Star Updates

On June 25, CMS released a QSO memo updating changes to the staffing and quality domains of Five-Star due to COVID-19. The updates include: 
  • Lifting the Payroll-Based Journal (PBJ) staffing data waiver. Nursing homes must submit calendar year Quarter 2 (April – June) 2020 PBJ data by August 14, 2020. This data will be used in Five-Star ratings updated in October 2020. 
  • Holding constant Five-Star Staffing ratings and measures from now through October 2020. Because submission of calendar year Quarter 1 (January – March) 2020 PBJ data remains optional, the staffing star ratings and measure will not be updated on the next Nursing Home Compare update on July 29, 2020. 
  • Updating Five-Star Quality ratings and measures on July 29, 2020. The quality measures will not reflect any assessments after December 31, 2019. There are several measures, mostly claims-based measures, that will be updated on Nursing Home Compare on July 29, 2020. Other measures that currently reflect data through December 31, 2019 will be held constant. 
Staffing Measures and Ratings Update

With this memo, CMS immediately ends the blanket emergency waiver of 42 CFR 483.70(q), which requires nursing home providers to submit staffing data through the Payroll-Based Journal (PBJ) system. This is a portion of the broader COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers, which largely remains in place. 

With the ending of the PBJ data submission waiver, facilities must submit the requisite staffing data for calendar Quarter 2 (April – June) 2020 through the PBJ system by August 14, 2020. 

Submission of calendar Quarter 1 (January – March) 2020 data was optional under the blanket waiver and remains so. CMS reports approximately 60 percent of facilities still submitted this data. While this data will not be used to calculate staffing measures or staffing ratings, it will be posted on CMS’s public use files available on data.cms.gov

Five-Star Staffing Star ratings currently on Nursing Home Compare are based on Quarter 4 (October – December) 2019 data. Ratings will continue to be based on this data till October 2020, when Quarter 2 (April – June) 2020 data is used. Quarter 1 (January – March) 2020 data will never be used to determine ratings. 

For facilities that currently have their Staffing Star ratings downgraded to one-star because of either missing the Quarter 4 – 2019 submission deadline or reporting four or more days with no RN hours, their staffing ratings and measures will temporarily be suppressed from July 29, 2020 through October 2020. This is because they will not have an opportunity to correct or improve their staffing ratings due to the PBJ data submission waiver.

Quality Measures and Ratings Update

Similar to the staffing data waiver, CMS previously waived requirements at 42 CFR 483.20 related to the timelines for completing and submitting resident assessment (minimum data set [MDS]) information. CMS believes data from assessments after January 1, 2020 cannot be used to calculate quality measures, but assessments prior to January 1, 2020 can be used.

On the next Nursing Home Compare update, which is scheduled for July 29, 2020, Five-Star quality ratings and measures will be updated using any underlying data that is available up to December 31, 2019. 

This is mostly applicable to claims-based measures, such as short-stay rehospitalization, which currently on Nursing Home Compare are through September 30, 2019. Other measures, such as the MDS-based pressure ulcer measure, already reflect assessments through December 31, 2019 and thus the rate will not change with the next Nursing Home Compare update. For a full list of measures and their current collection period, go to the “About the Data” page on Nursing Home Compare.

Health Inspections and Survey Ratings Update 

The Five-Star Survey rating domain remains frozen. CMS froze the survey domain to prioritize infection control surveys over standard, fire, and safety inspections. CMS is monitoring inspections and will restart survey ratings as soon as possible. When they are resumed will be communicated in a future memo.


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