On May 17, the Centers for Medicare & Medicaid Services (CMS) released its new Action Plan for Further Improvement of Nursing Home Quality (Action Plan). The Action Plan is CMS’ strategic plan for nursing homes that is published every four years. The 2016 Action Plan sets forth five coordinated sets of actions (Action Plan Elements) and describes in detail how CMS has been, and plans to continue, making progress on each element of the Action Plan.
The five Action Plan Elements are as follows: (1) enhance consumer awareness and assistance; (2) strengthen survey processes, standards, and training; (3) improve enforcement activities; (4) promote quality improvement; and (5) create strategic approaches through partnerships. Most of the action items are either ongoing or scheduled to occur in 2016. The paragraphs below highlight some specific activities and programs discussed in the Action Plan, organized by the five Action Plan Elements.
Enhance Consumer Awareness and Assistance
CMS is enhancing its five-star rating system, which assigns a star rating to each nursing home facility based upon three domains: (1) the past approximately three years of health inspections; (2) selected quality measures; and (3) staffing. CMS is currently evaluating additional quality measures for nursing home hospitalization, discharge to community, and functional status improvement. Staffing has historically been self-reported; however, beginning July 1, CMS will collect its staffing data from quarterly payroll-based data.
Strengthen Survey Process, Standards, and Training
CMS soon will issue final regulations revising and updating the State Operations Manual (SOM), Appendix PP Interpretive Guidance. In anticipation of these new participation requirements, CMS has issued tools to prepare nursing homes, including advance copies of Survey and Certification policy memos, satellite broadcasts, and other training tools.
CMS has been refining the Quality Indicator Survey (QIS) survey approach while continuing to evaluate the QIS survey process in comparison to the traditional survey process. CMS intends to combine the strengths of both the QIS and the traditional processes into a unified survey methodology to be implemented nationwide.
There is expanded access to web-based training for surveyors and CMS regional offices. Additionally, CMS is strengthening the consistency and quality of nursing home complaint intake and investigations at both the state survey agency and regional office levels.
Another area of focus for CMS is health care associated infections (HAIs). Surveyors are receiving additional training on HAIs, and CMS is partnering with the Centers for Disease Control and Prevention to address nursing home HAIs. Provider-focused HAI trainings may be made available in the future. CMS has published policy guidance to address specific processes that pose an infection control risk (i.e., reprocessing single-use devices and laundry) and intends to issue future policy guidance on urinary tract infections in nursing homes.
CMS regional office oversight of the state survey agencies will be increased in order to ensure that the State Performance Standards System for survey quality is being properly and consistently effected.
Improving Enforcement Activities
CMS has developed a Nursing Home Enforcement Strategic Action Plan that focuses on transparency and consistency in the application of enforcement remedies nationwide. Specifically, key action items include impending revisions to Chapter 7 of the SOM, which will expand the circumstances where civil monetary penalties are imposed, the publication of new online Nursing Home Enforcement Reports, new guidance regarding immediate jeopardy citations, and initiatives to monitor and improve special focus facility outcomes.
Promote Quality Improvement
CMS is updating the Minimum Data Set (MDS) 3.0 quality measures, expanding a five-state pilot for MDS-focused surveys, and standardizing MDS assessment tools and quality measures. There will be ongoing quality assurance and performance improvement (QAPI); however, the much–anticipated QAPI final rule still has yet to be issued. CMS has, however, developed tools and supports for nursing homes and surveyors designed to encourage a systems approach to improving quality and decreasing adverse events. Other CMS quality improvement efforts include the development of a five-state pilot for a dementia care-focused survey and its subsequent expansion.
Creating Strategic Approaches Through Partnerships
CMS seeks to encourage collaboration among key stakeholders (i.e., consumers, families, friends, providers, payers, professionals, state and federal agencies, quality improvement organizations, universities, and advocacy organizations). For example, cooperative efforts to improve nursing home care nationwide include: Quality Innovation Network-Quality Improvement Organization’s National Nursing Home Quality Care Collaboration, Advancing Excellence in America’s Nursing Homes Campaign, and CMS Nursing Home Convergence.