Michigan nursing facilities (NFs) participating in Medicaid can receive higher Quality Measure Incentive (QMI) payments if they promptly submit resident satisfaction survey data and documentation to the Michigan Department of Health and Human Services, Medical Services Administration (MSA). Don’t be lulled into complacency about submitting this data and documentation because you may have heard that the supplemental QMI program has not yet been approved by the federal Centers for Medicare and Medicaid Services (CMS).
In August of 2017, MSA notified Michigan NFs of a supplemental QMI payment program to pay additional Medicaid reimbursement to high quality NFs. See Policy Bulletin MSA 17-28, August 31, 2017. Under the new program, additional QMI payments would be based upon a combination of an individual NF’s average CMS Five Star quality rating, Medicaid utilization rate, number of licensed beds, and resident satisfaction survey data. Higher QMI payments would go to NFs with higher Five Star quality measure ratings, higher Medicaid utilization, and better compliance with submission rules for resident satisfaction survey data.
MSA proposed that these supplemental QMI payments begin October 1, 2017—but implementation of the plan is subject to CMS approval of a Medicaid State Plan amendment establishing it. To date, CMS has not approved the State Plan amendment. CMS contended that the proposed formula for determining the amount of supplemental QMI payments would improperly benefit NFs with low Medicaid utilization. Instead of an outright rejection of the proposed State Plan amendment, however, CMS permitted MSA to take the State Plan amendment “off the clock” in order to discuss changes that CMS could approve. The benefit of this process is that the State Plan amendment, and hence the supplemental QMI payments, will be retroactive to October 1, 2017 once CMS finally does approve the State Plan amendment. MSA currently believes that CMS will approve a modified formula.
Accordingly, MSA is moving forward with plans to implement the QMI supplement in anticipation of its approval. On April 23, 2018 MSA issued instructions about submission of resident satisfaction survey data. See MSA numbered letter L 18-24.
Effective for the rate year beginning on October 1, 2018, those NFs that properly submit acceptable resident satisfaction survey data and documentation will receive 100% of its standard QMI payment while a nursing facility that does not properly submit this data and documentation will receive only 85% of its standard payment. To be acceptable, NFs must submit the following resident satisfaction survey data and documentation:
- A copy of all the questions from the survey.
- A summary of the survey response results.
- The number of residents residing at the NF at the time of the survey.
- The number of residents who received the survey.
- The number of completed surveys, and a breakdown of who completed the survey for the residents.
- The survey date range.
- The survey frequency.
- The entity that conducted the survey.
- The survey data collection method(s).
- An explanation of how the NF uses the survey results to improve the quality of resident care.
To count toward the October 1, 2018 QMI payment calculation, the resident satisfaction survey must have been completed no earlier than 12 months prior to April 23, 2018, and must be submitted to MSA by August 17, 2018. NFs should send their resident satisfaction survey data and documentation electronically to the MSA Long Term Care Policy Section via email at MDHHS-NFQMI@michigan.gov.
Supplemental QMI payments can add up to significant additional dollars for NFs, particularly those larger facilities with high Medicaid utilization and a four or five Five Star quality measure rating. Don’t jeopardize these payments by failing to submit the required resident satisfaction survey data and documentation even though CMS has not yet formally approved the supplemental QMI program.