General

  1. Where can I find information for the Nursing Facility Pay for Performance (P4P) Program Fiscal Year (FY) 2014?
  2. What are the requirements of the NF P4P program?
  3. What are the application threshold requirements for this year’s NF P4P program?
  4. Where can my nursing facility obtain a copy of the Cooperative Effort policy attestation?
  5. Can MassHealth review my facility’s application for completeness before it is officially submitted?
  6. Whom should I contact if I have additional questions or need more information about the NF P4P program?
  7. What if my facility did not participate in the FY13 program but wants to participate in the FY14 program?
  8. What if my facility participated in the FY13 program and our application did not pass? Can we still participate in the FY14 program?
  9. If my facility participated in the FY13 program and passed the application, does it mean it automatically passes the FY14 application?
  10. Does my facility have to choose an option or measure to participate in the program?
  11. Will my facility be penalized if it does not have at least 10 residents eligible for a particular measure in the comparison data?

 

Cooperative Effort Policy

  1. What is a Cooperative Effort policy?
  2. Who on my nursing facility staff should be a member of the QC and attend all NF P4P program-related meetings?
  3. When should the QC meet?
  4. Does my facility have to provide a Cooperative Effort policy?
  5. What supporting materials do I need to submit to demonstrate the existence of a Cooperative Effort policy?
  6. Why does my nursing facility have to sign a Cooperative Effort policy attestation, and how should we submit it?
  7. Why might my nursing facility be audited? If audited, what audit activities will occur?
  8. How long will the audit process take?
  9. What is the selection process for an audit, and who will conduct the audits?

 

Quality Measure

  1. Why is my quality-measure score different than the score on Nursing Home Compare?
  2. Why is some of the information about the NF P4P quality measures (e.g., title and exclusions) different than what is provided in the CASPER report?
  3. What information can I expect to receive from MassHealth about the quality measures while participating in the program?
  4. Where can my facility find more information about how the quality-measure payment will be calculated?
  5. What if, after reading about the quality measure, my facility still has questions about the calculation process?

 

Application Process

  1. How can my nursing facility apply for the NF P4P program?
  2. When must OLTSS receive the application?
  3. What if my application is received after February 7, 2014?
  4. What provider ID should we provide in the application?
  5. What specific information should we include in the QC minutes?
  6. I am applying electronically and am restricted from including signed staff signatures in Table 1-QC Staff Roster. How do I submit them with my application?
  7. Is there a page limitation to the application?
  8. Can the application be sent electronically via e-mail?
  9. Can the application be sent as a hard copy? If so, what is the mailing address?

 

Payment

  1. If my facility’s application is accepted and we participate in this program, when will my facility be paid?
  2. What is the NF P4P budget for FY14?
  3. How much will my facility be paid?
  4. If my facility does not receive a payment in the spring of 2014 and wants to appeal the decision on its application, what is the process for appeals?
  5. If my facility qualifies for and is awarded incentive payments, who on my staff must be involved with determining how the incentive payments are spent?

 


 

General

  1. Where can I find information for the Nursing Facility Pay for Performance (P4P) Program Fiscal Year (FY) 2014?



    Nursing Facility Bulletin 137 provides information about the Nursing Facility Pay for Performance Program for FY14. It contains the following:
    • information about all program components (Cooperative Effort and quality measures);
    • description of the payment methodology;
    • a copy of the Nursing Facility P4P Program FY14 Application Form (Attachment A);
    • a sample filled-in application form (Attachment B);
    • Measure Specifications (Attachment C); and
    • Explanation of Performance Payment Methodology for the Quality Measures (Attachment D).

 

  1. 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 FY14 Application Form to the Office of Long Term Services and Supports (OLTSS) no later than the close of business on February 7, 2014. Several requirements for the program are outlined in Nursing Facility Bulletin 137. 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.

 

  1. 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.

    1. 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 within the time period of July 1, 2013, and June 30, 2014.
    2. Facilities must be enrolled as a MassHealth nursing facility for at least one day between July 1, 2013, and June 30, 2014.
    3. Facilities must have at least one paid MassHealth day during the measurement year of FY 2014 (July 1, 2013, through June 30, 2014).
    4. Facilities must demonstrate the existence of the Cooperative Effort policy.

 

  1. 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 FY14 Application Form. This form is available on the MassHealth website at www.mass.gov/masshealth. From this webpage, click on the MassHealth Provider Forms link on the right-hand side.

 

  1. 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.

 

  1. 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 OLTSS at NFP4PProgram@state.ma.us. OLTSS will make every attempt to respond to all e-mail inquiries within two business days of receipt.

 

  1. What if my facility did not participate in the FY13 program but wants to participate in the FY14 program?

    A nursing facility may apply to the FY14 program even if it did not participate in FY13.

 

  1. What if my facility participated in the FY13 program and our application did not pass? Can we still participate in the FY14 program?

    Yes. Any facility can participate in the FY14 program, even if it did not pass in FY13.

 

  1. If my facility participated in the FY13 program and passed the application, does it mean it automatically passes the FY14 application?

    No. Facilities that passed the FY13 application do not automatically pass the FY14 application.

 

  1. Does my facility have to choose an option or measure to participate in the program?

    No. The FY14 program does not involve a component selection. The program will measure facility performance on three quality-of-care measures: pressure sores, urinary tract infections, and use of antipsychotic medications.

    Facilities should not select a quality measure when applying for the program. Facilities will be measured and can become eligible for a performance payment for each of the three quality measures.

 

  1. Will my facility be penalized if it does not have at least 10 residents eligible for a particular measure in the comparison data?

    As long as the facility meets the 10-resident requirement for at least one of the three measures, the facility will be eligible to receive the same amount of payment (depending on performance) that it would have if it met the 10-resident requirement for all three measures.


 

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Cooperative Effort Policy

  1. 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 related to the selected quality measures. This committee must, at a minimum

    • meet at least quarterly throughout the year;
    • have appropriate members, including at least one Certified Nursing Assistant (CNA) or Geriatric Nursing Assistant (GNA), attend the meetings; and
    • work on the quality measure components of the NF P4P program.

 

  1. Who on my nursing facility staff should be a member of the QC and attend all NF P4P program-related meetings?

    Your QC committee team is formed by the administrator and includes members such as the staff-development nurse and director of nursing; however, for participation in the NF P4P program, the committee must include at least one CNA or GNA.

 

  1. When should the QC meet?

    To participate in this program, the QC must meet between October 1, 2013, and February 6, 2014, to discuss the P4P program.

 

  1. Does my facility have to provide a Cooperative Effort policy?

    Yes. To be eligible for the NF P4P FY14 program, your facility must provide a Cooperative Effort policy and meet all of the Cooperative Effort thresholds.

 

  1. 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.

    An example of an acceptable Cooperative Effort policy and meeting minutes is provided in Attachment B in the bulletin. Applications submitted without this supporting material will not be accepted. Other reasons for not accepting applications include the following:

    • QC minutes that are missing;
    • minutes submitted outside of the time frame provided (October 1, 2013, to February 6, 2014);
    • minutes or roster with missing or illegible attendee signatures;
    • absence of a CNA or GNA from the QC meeting;
    • missing signature from the attestation;
    • dates not corresponding on the meeting minutes or signed roster;
    • submission of application after the February 7, 2014, deadline;
    • minutes and roster that are incomplete or missing a date;
    • facility found in jeopardy or marked as a special focus facility between July 1, 2013, and June 30, 2014; or
    • minutes not indicating any NF P4P activity or activity on any of the three quality measures.

 

  1. 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

 

  1. Why might my nursing facility be audited? If audited, 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. 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.

 

  1. How long will the audit process take?

    OLTSS anticipates that the audit will take about one to two hours.

 

  1. What is the selection process for an audit, and who will conduct the audits?

    Facilities will be selected for an audit based on a random sampling of the total number of applications received. Facilities will be contacted by OLTSS if they have been selected for an audit. The NF P4P audits will be conducted by an OLTSS nurse reviewer in the spring of 2014.

 

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 Quality Measure

  1. 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.

 

  1. Why is some of the information about the NF P4P quality measures (e.g., title and exclusions) different than what is provided in the CASPER report?

    Though both reports measure similar items, the CASPER report and Nursing Home Compare (NHC) contain differences in methodology and reporting period, depending on the measure. For example, 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 UTI, pressure ulcer, and antipsychotic-medication quality measure from CMS using the specifications listed in NHC and located here. The specification for these measures is located on pages 22, 31, and 40 of the MDS Manual.

 

  1. What information can I expect to receive from MassHealth about the quality measures while participating in the program?

    A baseline report was sent to your facility in October 2013, and includes your facility’s scores for the selected quality measures, as well as the high-performance and attainment-thresholds (25th and 50th percentiles). If your facility submits a qualifying application, you will receive a second comparison report in the spring of 2014, which will include the same baseline score and thresholds from the original report, and the facility’s scores from the October-through-December 2013 comparison period.

 

  1. Where can my facility find more information about how the quality-measure payment will be calculated?

    Facilities should refer to Attachment D, Payment Methodology for Quality Measures within Nursing Facility Bulletin 137 to view more information on the quality-measure calculation and Appendix D: Explanation of Performance Payment Methodology for Quality Measures.

 

  1. 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.

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Application Process

  1. 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 137.

 

  1. When must OLTSS receive the application?

    All applications must be received on or before February 7, 2014.

 

  1. What if my application is received after February 7, 2014?

    Applications received after the February 7, 2014, deadline will not be processed, and those nursing facilities will not be able to participate in the program.

 

  1. What provider ID should we provide in the application?

    Applications should include the MassHealth provider ID number. Please refer to the sample application in the bulletin for an example provider ID number.

 

  1. What specific information should we include in the QC minutes?

    The minutes from the committee’s meeting should include only

    • the date of the meeting, which must correspond to date on the staff roster;
    • the names, titles, and signatures of attendees, with at least one CNA or GNA in attendance; and
    • notes on discussions about the quality measures.

    The QC should remove all notes on discussions about other items from the minutes.

 

  1. I am applying electronically and am restricted from including signed staff signatures in Table 1-QC Staff Roster. How do I submit them with my application?

    Signed staff signatures can be scanned and added to your application as an attachment. An example of an acceptable QC staff roster is provided in Attachment B in the bulletin. Please note that the staff roster date must correspond to the date of the submitted meeting minutes.

 

  1. Is there a page limitation to the application?

    The application should not exceed 10 pages.

 

  1. 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 7, 2014.

 

  1. 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

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Payment

  1. 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, and MassHealth must receive the application by the due date of February 7, 2014. If the facility’s application is accepted by MassHealth, each facility may receive a payment before June 30, 2014. Facilities may receive a payment provided that they meet Cooperative Effort thresholds, and 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.

 

  1. What is the NF P4P budget for FY14?

    The total FY14 budget for the NF P4P program is $2.8 million.

 

  1. How much will my facility be paid?

    The FY14 incentive payments will be distributed from the total amount of the NF P4P budget for FY14 (July 1, 2013, through June 30, 2014). Incentive payments will be based on high performance and improvement from baseline performance scores.

 

  1. If my facility does not receive a payment in the spring of 2014 and wants to appeal the decision on its application, what is the process for appeals?

    Your facility may appeal a payment determination in accordance with the Executive Office of Health and Human Services regulation at 101 CMR 206.09(2) by filing an appeal with the Division of Administrative Law Appeals, One Congress Street, 11th Floor, Boston, MA 02114. This appeal must be made within 30 days after this letter is filed with the Secretary of State in accordance with M.G.L. c. 118E, §13E, and the Standard Adjudicatory Rules of Practice and Procedure at 801 CMR 1.01.

 

  1. If my facility qualifies for and is awarded incentive payments, who on my staff must be involved with determining how the incentive payments are spent?

    The FY14 budget language requires that representatives of employees, including CNAs or GNAs, and management shall jointly discuss how to expend such incentive payments. Facilities should demonstrate compliance with this by signing the attestation located in the NF P4P application.

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