General
- Where is information for the Nursing Facility Pay for Performance (P4P) Program Fiscal Year (FY) 2013 available?
- What are the requirements of the NF P4P program?
- What are the application threshold requirements for this year’s NF P4P program?
- Where can my nursing facility obtain a copy of the Cooperative Effort policy attestation?
- Can MassHealth review my facility’s application for completeness before it is officially submitted?
- Whom should I contact if I have additional questions or need more information about the NF P4P program?
- What if my facility receives payment for the FY13 program and then decides to opt out of the program?
- What if my facility did not participate in the FY12 program but wants to participate in the FY13 program?
- What if my facility participated in the FY12 program and our application did not pass, can we still participate in the FY13 program?
- If my facility participated in the FY12 program and passed the application, does it mean it automatically passes the FY13 application?
- Does my facility have to choose an option to participate in the program?
Cooperative Effort Policy
- What is a Cooperative Effort policy?
- Nursing Facility Bulletin 135 notes (on pages 2 and 3) that the QC must focus on quality improvement efforts on a consistent staff assignment model of care. Does this apply to my facility if we select Option 1 (quality measure)?
- Who on my nursing facility staff should be a member of the QC and attend all NF P4P program-related meetings?
- When should the QC meet?
- Does my facility have to provide a Cooperative Effort policy?
- What supporting materials do I need to submit to demonstrate the existence of a Cooperative Effort policy?
- Why does my nursing facility have to sign a Cooperative Effort policy attestation and how should we submit it?
- Why might my nursing facility be audited and what audit activities will occur?
- How long will the audit process take?
Consistent Assignment
- What is consistent assignment?
- If my facility selects the consistent assignment option of the NF P4P program, what must I do?
- What tools are available to help my facility calculate consistent assignment scores?
- If I select the consistent assignment option, does my facility complete the consistent assignment tracking tool using the entire facility or can my facility select one unit?
- Should I submit my facility’s FY12 consistent assignment score with my facility’s FY13 consistent assignment score?
- Which Advancing Excellence tool for tracking consistent assignment should my facility use?
- Is my facility required to participate in the consistent assignment component of the program?
Quality Measure
- Why is my quality measure score different than the score on Nursing Home Compare?
- Why is some of the information pertaining to the NF P4P quality measure (e.g., title and exclusions) different than what is provided in the CASPER report?
- How can my nursing facility participate in the quality measure component of the program?
- What can I expect while participating in the quality measure component of the program?
- Where can my facility find more information about how the quality measure payment will be calculated?
- What if after reading about the quality measure my facility still has questions about the calculation process?
- Where can my facility find more information about how to improve my facility’s score on the quality measure?
- Is my facility required to participate in the quality measure option of the program?
Application Process
- How can my nursing facility apply for the NF P4P program?
- When is the application due to OLTSS?
- What if my application is received after February 6, 2013?
- Why do facilities need to enroll in Advancing Excellence?
- How can my nursing facility enroll in the Advancing Excellence in America’s Nursing Homes campaign?
- Can facilities use one of the other Advancing Excellence’s initiatives instead of consistent assignment?
- What specific information should be included in the QC minutes?
- Is there a page limitation to the application?
- Can the application be sent electronically via e-mail?
- Can the application be sent as a hard copy? If so, what is the mailing address?
Payment
- If my facility’s application is accepted and we participate in this program, when will my facility be paid?
- What is the NF P4P budget for FY13?
- How much will my facility be paid?
- If my facility does not receive a payment in the spring of 2013 and wants to appeal the decision on its application, what is the process for appeals?
General
Where is information for the Nursing Facility Pay for Performance (P4P) Program Fiscal Year (FY) 2013 available?
Nursing Facility Bulletin 135 supersedes Nursing Facility Bulletin 134. It provides information about the Nursing Facility Pay for Performance Program for FY13. It contains- information pertaining to all program components (Cooperative Effort, Consistent Assignment, and Quality Measure);
- payment methodology description;
- a copy of the Nursing Facility P4P Program FY13 Application Form (Attachment A);
- a sample filled-in application form (Attachment B);
- Measure Specification (Attachment C); and
- Explanation of Performance Payment Methodology for the Quality Measure (Attachment D).
What are the requirements of the NF P4P program?
To be considered for participation in the program, nursing facilities must submit a completed NF P4P Program FY13 Application Form to the Office of Long Term Services and Supports (OLTSS) no later than the close of business on February 6, 2013. Several requirements for the program are outlined in Nursing Facility Bulletin 135. All application and threshold requirements must be met in order for a facility to participate in the program. The threshold requirements include the existence of a Cooperative Effort policy, described in more detail below.
What are the application threshold requirements for this year’s NF P4P program?
To be considered eligible for the program, nursing facilities must meet the following four threshold requirements for the program.
- Facilities must not have an immediate jeopardy designation by the Massachusetts Department of Public Health or be designated by the Centers for Medicare & Medicaid Services (CMS) as a special focus facility between July 1, 2012, and June 30, 2013.
- Facilities must be enrolled as a MassHealth nursing facility for at least one day between July 1, 2012, and June 30, 2013.
- Facilities must have at least one paid MassHealth day during the measurement year of FY 2012 (July 1, 2012, through June 30, 2013).
- Facilities must demonstrate the existence of the Cooperative Effort policy.
Where can my nursing facility obtain a copy of the Cooperative Effort policy attestation?
The Cooperative Effort policy attestation is part of the Nursing Facility Pay for Performance Program FY13 Application Form. This form is available on the MassHealth website at www.mass.gov/masshealth. Click on the MassHealth Provider Forms link on the right hand side.
Can MassHealth review my facility’s application for completeness before it is officially submitted?
No. MassHealth will review only final applications submitted for the NF P4P program.
Whom should I contact if I have additional questions or need more information about the NF P4P program?
All questions about the NF P4P program should be sent to NFP4PProgram@state.ma.us. OLTSS will make every attempt to respond to all e-mail inquiries within two business days of receipt.
What if my facility receives payment for the FY13 program and then decides to opt out of the program?
If your facility receives a payment for the FY13 program and decides not to continue participating in the NF P4P FY13 program, the facility can refund MassHealth the exact amount of the payment it receives in the spring of 2013. For instructions on refunding incentive payments, please send an e-mail to NFP4PProgram@state.ma.us.
What if my facility did not participate in the FY12 program but wants to participate in the FY13 program?
Any nursing facility may apply to the FY13 program even if they did not participate in FY12.
What if my facility participated in the FY12 program and our application did not pass, can we still participate in the FY13 program?
Yes. Any facility can participate in the FY13 program, even if they did not pass in FY12.
If my facility participated in the FY12 program and passed the application, does it mean it automatically passes the FY13 application?
No. Facilities that passed the FY12 application do not automatically pass the FY13 application.
Does my facility have to choose an option to participate in the program?
Yes. Facilities must choose to participate in either the quality measure component (Option 1) of the program or the consistent assignment component (Option 2) of the program. Facilities cannot participate in both. Facilities must complete and submit the Component Selection page from the NF P4P Program Application for FY13.
Cooperative Effort Policy
What is a Cooperative Effort policy?
A Cooperative Effort policy is defined as the establishment of a committee whose purpose is to help improve quality of care within a facility for the NF P4P program. The NF P4P program does not envision that individual nursing facilities will create a new committee for this program. The policy can leverage the resources used for the Quality Assurance Committee (QC) that currently exists within facilities to focus on quality improvement efforts on a consistent staff assignment model of care. This committee must, at a minimum,
- meet at least quarterly throughout the year;
- have appropriate members, including at least one Certified Nursing Assistant (CNA)/Geriatric Nursing Assistant (GNA), attend the meetings; and
- work on either the consistent assignment or quality measure components of the NF P4P program.
Nursing Facility Bulletin 135 notes (on pages 2 and 3) that the QC must focus on quality improvement efforts on a consistent staff assignment model of care. Does this apply to my facility if we select Option 1 (quality measure)?
No. If your facility chooses Option 1, then the QC may discuss quality measure-related information. Additionally, if your facility is audited, the audit will focus on the option your facility selects, either the quality measure or the consistent assignment component.
Who on my nursing facility staff should be a member of the QC and attend all NF P4P program-related meetings?
Any member of your team can be a member of the QC. However, for participation in the NF P4P program, the committee must include at least one CNA/GNA.
When should the QC meet?
To participate in this program, the QC must meet between October 1, 2012, and February 5, 2013, to discuss the Pay for Performance Program.
Does my facility have to provide a Cooperative Effort policy?
Yes. To be eligible for the NF P4P FY13 program, your facility must provide a Cooperative Effort policy and meet all of the cooperative effort thresholds.
What supporting materials do I need to submit to demonstrate the existence of a Cooperative Effort policy?
The facility must sign and return the attestation, which is part of the application form, indicating compliance with this policy. Along with the attestation, the facility must also submit a copy of its written Cooperative Effort policy and minutes from the last QC meeting. Minutes must include names, titles, and signatures of the members attending the meeting. Information that does not pertain to the NF P4P program must be redacted from the minutes submitted to MassHealth.
Why does my nursing facility have to sign a Cooperative Effort policy attestation and how should we submit it?
Submitting the attestation is a requirement for participation in the program. It ensures that nursing facilities understand and are in compliance with the Cooperative Effort policy requirement for the NF P4P program. Nursing facilities should submit their signed attestation along with their application electronically to MassHealth at NFP4PProgram@state.ma.us. Nursing facilities can also send the application by U.S. mail to the following address.
Nursing Facility Pay for Performance Program Office of Long Term Services and Supports
One Ashburton Place, 5th Floor
Boston, MA 02108
Why might my nursing facility be audited and what audit activities will occur?
Nursing facilities may be audited to ensure that the Cooperative Effort policy is being met. Audit activities will be conducted by OLTSS to confirm the existence of a QC. Not all facilities will be audited but it is expected that all facilities will cooperate with OLTSS if audited. The audit may include asking nursing facilities to provide documentation (e.g., QC meeting agendas and minutes; staff roster) and conducting onsite interviews with QC staff. If a facility does not comply with the audit, its application will not be accepted and it will not be eligible to receive the incentive.
How long will the audit process take?
If a facility is audited, OLTSS anticipates that the audit will take about one to two hours.
Back to Cooperative Effort Policy Questions
Consistent Assignment
What is consistent assignment?
Consistent assignment is defined by Advancing Excellence as being regularly cared for by the same caregiver.
If my facility selects the consistent assignment option of the NF P4P program, what must I do?
Nursing facilities that choose the consistent assignment component of the program must enroll in the Advancing Excellence in America’s Nursing Homes Campaign, as described at www.nhqualitycampaign.org/star_index.aspx?controls=PreviewGoals (Copy and paste this link into your Internet browser to get to the appropriate page.) and select Explore Goal, then Goal Selections.
You will need to sign in to select the consistent assignment goal. Facilities must submit with their application a copy of the Data for Website Entry worksheet from the Consistent Assignment Tracking Tool, which contains a snapshot of your facility’s consistent assignment data.
What tools are available to help my facility calculate consistent assignment scores?
Facilities may refer to Advancing Excellence’s implementation guide for improving consistent assignment of nursing home staff available at http://www.nhqualitycampaign.org/files/impguides/2_ConsistentAssignment_TAW_Guide.pdf. Materials, including Advancing Excellence’s Consistent Assignment Tracking Tool, can be found on Advancing Excellence’s website at http://www.nhqualitycampaign.org/star_index.aspx?controls=PreviewGoals, by selecting Consistent Assignment: Identify Baseline, and then selecting Consistent Assignment Tracking Tool at www.nhqualitycampaign.org/files/tools/AE_ConsistentAssignmentTRACKINGTOOL_v2.3_2-4-13.xls.
If I select the consistent assignment option, does my facility complete the consistent assignment tracking tool using the entire facility or can my facility select one unit?
Advancing Excellence allows facilities to use the tool for either their entire facility or a unit. Given this, the NF P4P program will allow facilities to submit the tracking tool with either the facility or unit data.
Should I submit my facility’s FY12 consistent assignment score with my facility’s FY13 consistent assignment score?
No. Advancing Excellence changed the methodology for calculating consistent assignment performance, so the FY12 scores cannot be compared.
Which Advancing Excellence tool for tracking consistent assignment should my facility use?
Facilities will have access to the Consistent Assignment tool once they enroll with Advancing Excellence. Advancing Excellence has updated their consistent assignment goal as of December 2012. Facilities must use the Consistent Assignment Tracking Tool with Volume 2 in its title which is located at http://www.nhqualitycampaign.org/star_index.aspx?controls=consistentassignmentidentifybaseline. Facilities will need to click on the link to V2.2 www.nhqualitycampaign.org/files/tools/AE_ConsistentAssignmentTRACKINGTOOL_v2.3_2-4-13.xls and follow the instructions for completing the tool.
Is my facility required to participate in the consistent assignment component of the program?
No. Consistent assignment (Option 2) is one of the two options a facility may select.
Back to Consistent Assignment Questions
Quality Measure
Why is my quality measure score different than the score on Nursing Home Compare?
Minimum Data Set (MDS) 3.0 data reports, which nursing facilities submit to CMS, are calculated somewhat differently than the facility scores posted on CMS’s Nursing Home Compare (NHC) website. NHC scores represent a moving average of three quarters of data (i.e., nine months), whereas MDS data represents only one quarter at a time. Therefore, you may find that your facility’s quality measure score, as listed on the Quality Measure Baseline Report, is not the same as the score posted on the NHC website.
Why is some of the information pertaining to the NF P4P quality measure (e.g., title and exclusions) different than what is provided in the CASPER report?
The CASPER report uses a different psychoactive medication quality measure (including different exclusions) than the NF P4P quality measure that is derived from Nursing Home Compare (NHC). Accordingly, MassHealth receives data for the antipsychotic medication quality measure from CMS using the specifications listed in NHC and located at http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/Downloads/MDS-30-QM-Users-Manual-V60.pdf. The specification for this measure is located on page 40 of the MDS Manual.
Please Note: The quality measure title used in the Quality Measure Baseline Report (issued in October 2012) has changed to clearly reflect the NHC’s measure title. .
How can my nursing facility participate in the quality measure component of the program?
By selecting the quality measure option (Option 1) and submitting a qualifying application to MassHealth, your facility will be eligible to participate in the quality measure component. However, to receive a Quality Measure Comparison Report, your facility must have passed the cooperative effort component of the program, as outlined in the application. Your facility must also have at least 10 residents who meet the requirements for the quality measure as defined by CMS.
What can I expect while participating in the quality measure component of the program?
If your facility selects to participate in the quality measure option and submits a qualifying application, MassHealth will mail two reports to your facility through the course of the FY13 program. The first report was sent in October 2012, and includes your facility’s score for the selected quality measure as well as the high performance threshold and attainment threshold (25th and 50th percentiles). Your facility will receive a second report in May 2013, which will include the same baseline score and thresholds from the original report and the facility’s score from the October through December 2012 comparison period.
Where can my facility find more information about how the quality measure payment will be calculated?
Facilities should refer to Step 3: Quality Measure within Nursing Facility Bulletin 135 to view more information on the quality measure calculation.
What if after reading about the quality measure my facility still has questions about the calculation process?
Facilities may submit e-mails to the NF P4P program e-mail account at NFP4PProgram@state.ma.us to receive further clarification on any component of the program.
Where can my facility find more information about how to improve my facility’s score on the quality measure?
MassHealth does not endorse a particular program or method of attaining improvement on the quality measure, except that it is clinically sound and in the best interest of our members. There are programs in this area that we have been made aware of: www.alz.org/alzheimers_disease_treatments_for_behavior.asp#medications www.maseniorcare.org Alzheimer's Association and OASIS. The latter has a link found on the Massachusetts Senior Care Association website.
Is my facility required to participate in the quality measure option of the program?
No. Quality measure (Option 1) is one of the two options a facility may select.
Back to Quality Measure Questions
Application Process
How can my nursing facility apply for the NF P4P program?
Facilities must submit an application to MassHealth in order to be considered for participation. Applications must be completed by the QC as indicated in Nursing Facility Bulletin 135.
When is the application due to OLTSS?
All applications must be submitted on or before February 6, 2013.
What if my application is received after February 6, 2013?
Applications received after the February 6, 2013, deadline will not be processed and those nursing facilities will not be able to participate in the program.
Why do facilities need to enroll in Advancing Excellence?
Facilities that select the consistent assignment component (Option 2) need to enroll in Advancing Excellence to provide the appropriate documentation on consistent assignment for its application. Enrolling in Advancing Excellence helps facilities to implement a consistent assignment quality improvement project and use tools necessary to track performance of the project.
How can my nursing facility enroll in the Advancing Excellence in America’s Nursing Homes campaign?
Facilities can enroll in Advancing Excellence’s campaign by registering online at http://www.nhqualitycampaign.org/star_index.aspx?controls=registration_nh.
Can facilities use one of the other Advancing Excellence’s initiatives instead of consistent assignment?
For participation in the NF P4P program, facilities must select either consistent assignment or the quality measure component of the program, and not any other of Advancing Excellence’s initiatives.
What specific information should be included in the QC minutes?
As the QC is established specifically for the NF P4P program, minutes from the committee’s meeting should only include
- the date of the meeting;
- the names, titles, and signatures of attendees, with at least one certified nursing assistant (CNA)/geriatric nursing assistant (GNA) in attendance; and
- notes on discussions pertaining to consistent staff assignment activities.
All notes on discussions that the QC had on other items should be removed from the minutes.
Is there a page limitation to the application?
The application should not exceed 15 pages.
Can the application be sent electronically via e-mail?
Yes. Facilities are strongly encouraged to submit their application electronically via e-mail to NFP4PProgram@state.ma.us. This e-mail must be received by midnight, February 6, 2013.
Can the application be sent as a hard copy? If so, what is the mailing address?
Yes. MassHealth will accept hard copies of the application, though electronic copies are strongly preferred. Hard copies must be typed. A hard copy application should be sent to the following address.
Nursing Facility Pay for Performance Program
Office of Long Term Services and Supports
One Ashburton Place, 5th Floor
Boston, MA 02108
Back to Application Process Questions
Payment
If my facility’s application is accepted and we participate in this program, when will my facility be paid?
Facilities must meet all of the requirements for the NF P4P program, select either the quality measure or consistent assignment component, and submit an application by the due date of February 6, 2013. If the facility’s application is accepted by MassHealth, each facility may receive a payment for their selected option before June 30, 2013, if they are eligible for the payment. Facilities may receive a payment for their selected option, provided, they meet cooperative effort thresholds,
- if selecting the consistent assignment component, submit consistent assignment scores as outlined in Nursing Facility Bulletin 135; or
- if selecting the quality measure component, perform to the specifications of the quality measure payment methodology outlined below:
- meet or perform better than the 25th percentile high performance threshold for the quality measure; or
- meet or perform better than the 50th percentile attainment threshold for the quality measure; or
- demonstrate improvement over their baseline score.
What is the NF P4P budget for FY13?
The total FY13 budget for the NF P4P program is $1.4 million. Under the authority of M.G.L.c.29, §9C, the allotment of funds for the FY13 Nursing Facility Pay for Performance (NF P4P) program budget was reduced from $2.8 million to $1.4 million.
How much will my facility be paid?
The FY13 incentive payments will be distributed from the total amount of the NF P4P budget for FY13 (July 1, 2012, through June 30, 2013). The $1.4 million will be split proportionally between the consistent assignment and quality measure components of the program, based on the number of facilities choosing a specific option. For example, if 300 facilities choose and are eligible for payment for the quality measure option and 100 facilities choose and are eligible for payment for the consistent assignment option, $1.05 million will be allotted to the quality measure with the remaining $350,000 allotted to the consistent assignment component.
If my facility does not receive a payment in the spring of 2013 and wants to appeal the decision on its application, what is the process for appeals?
Please submit all appeals to the following address.
Nursing Facility Pay for Performance Program
Office of Long Term Services and Supports
One Ashburton Place, 5th Floor
Boston, MA 02108
