Where can I find information about the Nursing Facility Pay for Performance (P4P) Program Fiscal Year (FY) 2016?
Nursing Facility Bulletin 140 provides information about the Nursing Facility Pay for Performance (NF P4P) Program for FY16. It contains the following.
- Information about all program components (cooperative effort and quality and staffing measures)
- A comparison of program requirements between the FY14 and FY16 NF P4P Programs (Attachment A)
- A copy of the Nursing Facility P4P Program FY16 Eligibility Attestation Form (Attachment B)
- A sample of required P4P program documentation (Attachment C)
- Quality and Staffing Measure Specifications (Attachment D)
- Explanation of Performance Payment Methodology for the Quality and Staffing Measures (Attachment E)
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 FY16 Eligibility Attestation Form to the Office of Long Term Services and Supports (OLTSS) no later than the close of business on February 4, 2016. Several requirements for the program are outlined in Nursing Facility Bulletin 140 . In order for a facility to participate in the program, it must submit a signed attestation and all 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 threshold eligibility 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 within the time period of July 1, 2015, to June 30, 2016.
- Facilities must be enrolled as a MassHealth nursing facility for at least one day between July 1, 2015, and June 30, 2016.
- Facilities must have at least one paid MassHealth day during the measurement year of FY 2016 (July 1, 2015, through June 30, 2016).
- Facilities must establish or demonstrate the existence of a cooperative-effort policy and committee whose purpose is to help improve the quality of care within a facility for the NF P4P program. Please refer to Page 2 of bulletin for additional information about the specific cooperative-effort policy requirements.
Where can my nursing facility obtain a copy of the eligibility attestation form?
The Eligibility Attestation Form is part of the Nursing Facility Pay for Performance Program FY16 Bulletin. This form is available on the MassHealth website at www.mass.gov/eohhs/docs/masshealth/provider-services/forms/nf-p4p-app.pdf .
Whom should I contact if I have additional questions or need more information about the NF P4P program?
Send all questions about the NF P4P program to NFP4PProgram@state.ma.us. OLTSS will make every attempt to respond to all e-mail inquiries within two business days of receipt.
Can my facility participate in the FY16 program if we did not participate in the FY14 program?
Yes. Any nursing facility may apply to the FY16 program even if it did not participate in FY14.
Can my facility participate in the FY16 program if we applied for participation in the FY14 program, but our application was not accepted?
Yes. Any facility may apply to the FY16 program, even if the facility’s application was not accepted in FY14.
If my facility applied to participate in the FY14 program and was accepted, is my facility automatically accepted for the FY16 program?
No. Facilities that were accepted to the FY14 program are not automatically accepted to the FY16 program. To be considered for participation in the program, facilities must meet all FY16 eligibility requirements and submit a signed Eligibility Attestation Form to MassHealth certifying compliance with those requirements.
Does my facility have to choose an option or measure to participate in the program?
No. The FY16 program does not involve a component selection. The program will measure facility performance on two quality-of-care measures and one staffing measure: use of antipsychotic medications and control of bowel and bladder; and total nursing staff average hours per resident per day.
Will my facility be penalized if it does not have at least 10 residents eligible for a particular measure in the quality data?
No. Qualifying facilities will be eligible for payment only for those quality measures for which they have at least 10 or more measure-eligible residents who had an MDS assessment during the measurement period. However, smaller qualifying facilities that do not meet the 10 eligible resident requirements will still be eligible to receive payment for performance on the staffing measure. The staffing measure does not have this resident requirement.
What information must my facility submit to participate?
Facilities must submit a signed and dated Eligibility Attestation Form no later than 11:59 pm on February 4, 2016. Attestations missing a signature or submitted after the February 4, 2016, deadline will not be accepted. Facilities are required to e-mail a scanned copy of their signed attestation to NFP4PProgram@state.ma.us. We will not accept hard-copy attestations.
What is a cooperative-effort policy?
A cooperative-effort policy is defined as the establishment of a committee whose purpose is to help improve the quality of care within a facility. The NF P4P program does not envision that individual nursing facilities will necessarily create a new committee for this program. The facility may, for instance, leverage the resources present in its current Quality Assessment and Assurance Committee (QAA) to focus on quality-improvement efforts related to the NF P4P program. This committee must, at a minimum
- meet at least quarterly throughout the year;
- have appropriate members, including at least one Certified Nursing Assistant (CNA); and
- discuss and work on quality-improvement efforts that focus on the MassHealth NF P4P Program
Who on my nursing facility staff should be a member of the committee and attend all NF P4P program-related meetings?
Your committee team is formed by the administrator and includes members such as the staff development nurse and the director of nursing. However, for participation in the NF P4P program, the committee must include at least one CNA.
When should the committee meet?
To participate in this program, the committee must meet between October 1, 2015, and February 3, 2016, to discuss the P4P program.
What supporting materials do I need to submit to demonstrate the existence of a cooperative-effort policy?
The facility must sign and return the Eligibility Attestation Form indicating compliance with this policy. Additional supporting materials do not need to be submitted to OLTSS with the attestation. However, the facility must maintain a copy of its written cooperative-effort policy and minutes from at least one committee meeting during the specified time period. Minutes must include names, titles, and signatures of the members attending the meeting, and information about the discussion of the MassHealth NF P4P Program or its quality or staffing measures. Information unrelated to the NF P4P program should be redacted if the minutes must be submitted to OLTSS. The facility must submit these documents for review by OLTSS if the facility submitting the attestation is audited, or otherwise upon request of OLTSS. These documents must be submitted to the OLTSS representative at the time of the audit or request.
An example of an acceptable cooperative-effort policy and meeting minutes is provided in Attachment C in Nursing Facility Bulletin 140 . Examples of documentation that would be unacceptable include the following.
- Missing committee meeting minutes
- Committee minutes outside the required time frame (October 1, 2015, to February 3, 2016)
- Minutes or roster with missing or illegible attendee signatures
- No evidence that a CNA attended the committee meeting
- Missing or inconsistent dates on the meeting minutes or signed roster
- Incomplete minutes or roster
- Minutes that do not indicate any NF P4P activity or activity on any of the quality measures or staffing measure
- Minutes that do not match the corresponding agenda
Why does my nursing facility have to sign a cooperative-effort policy attestation, and how should we submit it?
Submitting the attestation ensures that nursing facilities understand and are in compliance with the cooperative-effort policy requirement for the NF P4P program. Nursing facilities must scan and submit their signed Eligibility Attestation Form electronically to MassHealth at NFP4PProgram@state.ma.us. We will not accept hard-copy attestations.
Why might my nursing facility be audited? If it is, what audit activities will occur?
Nursing facilities may be audited to ensure that the eligibility and cooperative-effort policy requirements have been met. OLTSS will conduct the audit activities to confirm the existence of a cooperative-effort committee or that there are appropriate discussions at the facility’s QAA. It is expected that all facilities will cooperate with OLTSS if audited. The audit may include conducting onsite interviews with staff and requesting that nursing facilities provide the following documentation.
- A copy of the facility’s up-to-date cooperative-effort policy (a policy from FY2014 is not acceptable)
- The committee roster
- Meeting agendas that match submitted meeting minutes
- Meeting minutes with matching date, printed names, titles, and signature of attendees
If a facility does not comply with an audit or other request for documentation by OLTSS, it will not be eligible to receive incentive payments.
How long will the audit process take?
OLTSS anticipates that an audit will take between one and two hours.
Quality and Staffing Measures
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 is not the same as the score posted on the NHC website.
Why is some of the information about the NF P4P quality measures (e.g., title and exclusions) different than what the CASPER report provides?
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 antipsychotic medication and loss of bowel or bladder control quality measure from CMS using the specifications listed in NHC and located at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/Downloads/MDS-30-QM-User%E2%80%99s-Manual-V80.pdf. The specifications for these measures are located on page 32 and 40 of the MDS Manual.
Where can I find more information about the staffing measure?
You can find more information in the Technical User’s Guide located at www.cms.gov/medicare/provider-enrollment-and-certification/certificationandcomplianc/downloads/usersguide.pdf.
What information can I expect to receive from MassHealth about the quality and staffing measures while participating in the program?
Your facility will receive a report in the spring of 2016, which will include the facility’s scores from the July through December 2015 measurement period.
Where can my facility find more information about how the quality and staffing measure payment will be calculated?
Facilities should refer to Attachment E, Payment Methodology for Quality Measures within Nursing Facility Bulletin 140 to view more information on the quality and staffing measure calculation.
What if, after reading about the quality and staffing measures, 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.
How can my nursing facility apply for the NF P4P program?
Facilities must submit an Eligibility Attestation Form to OLTSS in order to be considered for participation. Applications must be completed by the facility as indicated in Nursing Facility Bulletin 140 .
When must OLTSS receive the attestation?
All attestations must be submitted on or before February 4, 2016.
What if my attestation is received after February 4, 2016?
Attestations received after the February 4, 2016, deadline will not be processed, and those nursing facilities will not be able to participate in the program.
What specific information should be included in the committee minutes?
Minutes from the committee’s meeting should include the following.
- 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 in attendance
- Notes on discussions about quality or staffing measures
The committee should remove all notes on discussions about other items from the minutes if the minutes must be submitted to OLTSS.
Can the attestation be sent electronically via e-mail?
Yes. Facilities must scan and submit their attestation electronically via e-mail to NFP4PProgram@state.ma.us. This e-mail must be received by11:59 p.m., February 4, 2016. We will not accept hard-copy attestations.
How can my facility qualify for an incentive payment?
Facilities must meet all of the requirements for the NF P4P program outlined in the bulletin and submit an attestation by February 4, 2016. Eligible facilities may qualify for a payment if these requirements are met, the attestation is received by the due date, and the facility performs to the specifications of the quality and staffing measure payment methodology outlined below:
- meet or perform better than the 25th percentile high-performance threshold for the quality measure;
- meet or perform better than the 50th percentile attainment threshold for the quality or staffing measure; or
- meet or perform better than the 75th percentile high-performance threshold for the staffing measure.
If my facility qualifies for an incentive payment, when will my facility be paid?
Payments to qualifying facilities will be made by June 30, 2016.
What is the NF P4P budget for FY16?
The total FY16 budget for the NF P4P program is $2.8 million.
How much will my facility be paid?
The FY16 incentive payments will be distributed from the total amount of the NF P4P budget for FY16 (July 1, 2015, through June 30, 2016). Incentive payments will be based on high- performance and attainment thresholds.
If my facility does not receive a payment in the spring of 2016 and wants to appeal the decision on its attestation, 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 information 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.
If my facility qualifies for and receives incentive payments, who on my staff must be involved with determining how the incentive payments are spent?
The FY16 budget language requires that representatives of employees, including CNAs and management, shall jointly discuss how to expend such incentive payments. Submission of a signed attestation obligates a facility to comply with this requirement.