On June 25, CMS outlined changes that affect the Staffing and Quality domains of the Five Star Rating system.

Staffing

First and perhaps most importantly, CMS ended the emergency waiver that allowed facilities to skip reporting their PBJ staffing data. Facilities must now report PBJ data for 2020Q2 by August 14.

Second, because the waiver was in effect for all of 2020Q1, CMS is "holding the Staffing Rating constant", meaning that the Star Ratings will be frozen starting in July and likely ending in October, when new data will be available. Facilities relegated to one star because of a failure to submit data will now instead receive no rating.

From our perspective, there seemed to be few alternatives, so this was a logical move. Since some facilities did submit staffing data for 2020Q1, CMS will publish that data, but it will not be used towards the Star ratings.

Quality

Similar to the staffing data submission waiver, CMS issued a waiver for resident assessment (MDS) submission starting on January 1, 2020. Unlike staffing however, this waiver has not yet been lifted, meaning that facilities are still exempted from reporting MDS data for Star Rating purposes.

MDS data powers 10 of the 17 QMs, and those QMs will be frozen starting in July. Because QMs are based on a 4-quarter average of MDS data, we expect that these QMs will be frozen for more than a year. As an alternative, CMS may just decide to drop 2020Q1 (and potentially 2020Q2) from the averages.

The memo also makes no mention of what will happen with claims-based measures, the first of which will cycle into 2020Q1 data in October. While the claims data shouldn't be affected by the MDS submision waiver, CMS has expressed wider concern about data collected during the COVID-19 emergency. We'll wait to see what happens.

Critically, CMS is not freezing QM Ratings, just individual QMs.

As always, our StarAnalyzer product will be updated to reflect the latest changes. Try running a sample search today to see how a facility near you has been affected.

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