Many changes will impact the social determinants of health.
On May 8, the Centers for Medicare & Medicaid Services (CMS) announced a delay in implementation of updated assessment instruments for Inpatient Rehabilitation Facilities (IRFs), Long-Term Care Hospitals (LTCHs), home health, and Skilled Nursing Facilities (SNFs). Details can be located online here: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/IRF-Quality-Reporting/Spotlights-Announcements.
The delays impact both the transfer of health information in quality measures and the new and revised Standardized patient Assessment Data Elements (SPADEs) – many of which relate to social determinants of health (SDoH) and are included in the updated assessment instruments that were to be implemented this fall.
Inpatient Rehabilitation Facilities and Long-Term Care Hospitals
The announcement reads:
Delayed: Release of Updated Versions of IRF and LTCH Assessment Instruments (and Supporting Training)
CMS is delaying the release of updated versions of the item sets needed to support the Transfer of Health (TOH) Information Quality Measures and new or revised Standardized Patient Assessment Data Elements (SPADEs) in order to provide maximum flexibilities for providers of Inpatient Rehabilitation Facilities (IRFs) and Long-Term Care Hospitals (LTCHs) to respond to the COVID-19 Pubic Health Emergency (PHE).
The release of updated versions of the IRF Patient Assessment Instrument (IRF-PAI) and the LTCH Continuity Assessment Record and Evaluation Data Set (LTCH CARE Data Set) will be delayed until Oct. 1 of the year that is at least one full fiscal year after the end of the COVID-19 PHE. For example, if the COVID-19 PHE ends on Sept. 20, 2020, LTCHs and IRFs will be required to begin collecting data using the updated versions of the item sets beginning with patients discharged on Oct. 1, 2021.
Home Health
The announcement reads:
Delayed: Release of Updated Version of the Home Health Assessment Instrument (and Supporting Training)
CMS is delaying the release of the updated version of the Outcome and Assessment Information Set (OASIS) needed to support the Transfer of Health (TOH) Information Quality Measures and new or revised Standardized Patient Assessment Data Elements (SPADEs) in order to provide maximum flexibilities for providers of Home Health Agencies (HHAs) to respond to the COVID-19 Pubic Health Emergency (PHE).
The release of the updated version of the OASIS will be delayed until Jan. 1 of the year that is at least one full calendar year after the end of the COVID-19 PHE. For example, if the COVID-19 PHE ends on Sept. 20, 2020, HHAs will be required to begin collecting data using the updated versions of the item sets beginning with patients discharged on Jan. 1, 2022.
Skilled Nursing Facilities
The announcement reads:
Delayed: Release of Updated Versions of SNF Assessment Instrument (and Supporting Training)
CMS is delaying the release of the updated versions of the Minimum Data Set (MDS) needed to support the Transfer of Health (TOH) Information Quality Measures and new or revised Standardized Patient Assessment Data Elements (SPADEs) in order to provide maximum flexibilities for providers of Skilled Nursing Facilities (SNFs) to respond to the COVID-19 Pubic Health Emergency (PHE).
The release of updated versions of the MDS will be delayed until Oct. 1 of the year that is at least two full fiscal years after the end of the COVID-19 PHE. For example, if the COVID-19 PHE ends on Sept. 20, 2020, SNFs will be required to begin collecting data using the updated versions of the item sets beginning with patients discharged on Oct. 1, 2022.
What This Means for Post-Acute Facilities
The delays allow all PAC settings more flexibility in dealing with current issues related to the PHE, and more time to prepare for changing documentation requirements.
Our Advice to Providers
Don’t lose focus on the requirements! At some point, the current waivers and flexibilities will expire, and PAC providers will once again be held accountable for compliance with regulatory requirements. Further, we believe that there will be audits related to care provided during this time to determine that the requirements not covered by a waiver were met, and that the requirements for the waivers were also met. As always, documentation is the key. To the extent possible, providers need to continue strong compliance practices and preparations for the upcoming implementations, as well continue to have strong documentation practices to support their efforts during the PHE.
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