In this CMS memo dated June 25, 2020, CMS addressed changes to staffing information and quality measures posted on the Nursing Home Compare Website and Five Star Quality Rating System due to the COVID-19 Public Health Emergency.
Payroll Based Journal (PBJ) Waiver Ended; 2nd quarter due August 14, 2020
CMS ended the PBJ emergency blanket waiver of staffing data submission requirement. All nursing homes will be required to resume submission of staffing data for Calendar Quarter 2 (April – June) 2020 through the PBJ system by August 14, 2020. Five-star staffing measures and ratings will be updated in October 2020 based on data submitted by August 14, 2020. In addition, while not required, CMS encourages nursing homes to submit data for Calendar Quarter 1 (January – March) 2020. Calendar Quarter 1 data will not be used to calculate staffing measures or ratings; however, CMS will continue to post the data in a public use file on data.cms.gov.
Staffing Measures and Ratings
Although CMS waived the requirement for Quarter 1 staffing data submission, approximately 60 percent of facilities still submitted their data. However, because of the waiver, CMS will not be able to update the PBJ staffing measures and staffing domain star ratings at the next regularly scheduled update in July 2020. Therefore, on July 29, 2020, staffing measures and ratings will be held constant, and based on data submitted for Calendar Quarter 4 (October – December) 2019. CMS acknowledges the waiver of the requirement prevented some facilities from improving their rating from their previous quarter’s submission. Thus, facilities whose staffing rating was automatically downgraded to one-star due to missing the deadline for the previous submission, or for reporting four or more days in the quarter with no registered nurse, now will not have the opportunity to correct and improve their staffing rating since the ratings will be held constant. Therefore, CMS will remove the one-star staffing rating downgrade, and instead, these facilities will have their measures and ratings temporarily suppressed.
CMS continues to emphasize the importance of staffing based on its relationship to quality.
Similar to the staffing data waiver, CMS waived requirements related to the timelines for completing and submitting resident assessment MDS information. This information provides the underlying data used to calculate quality measures used on the Nursing Home Compare website and Five Star Quality ratings system. CMS believes that data from resident assessments conducted prior to January 1, 2020, can still be used to calculate quality measures. However, we are concerned that data from resident assessments conducted after January 1, 2020 are impacted by the waiver and the public health emergency. Therefore, beginning July 29, 2020, quality measures based on data collection period ending December 31, 2019 will be held constant. Quality measures that are based on a data collection period prior to December 31, 2019 (e.g., ending September 30, 2019); however, will continue to be updated until the underlying data reaches December 31, 2019. Please note that CMS is not holding quality measure ratings constant, as a facility’s quality measure rating can still be updated by a quality measure with underlying data that is earlier than December 31, 2019.
Health Inspections and Ratings
CMS is continuing to monitor inspections, including the restarting of certain inspections (i.e., surveys) per CMS memorandum QSO-20-31-ALL. CMS will restart the inspection ratings as soon as possible, and will communicate any changes to stakeholder in advance of updating the Nursing Home Compare website.