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Nursing Facility Bulletin 140 provides information about the Nursing Facility Pay for Performance (NF P4P) Program for FY16. It contains the following.
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.
To be considered eligible for the program, nursing facilities must meet the following four threshold requirements for the program.
The Eligibility Attestation Form is part of the Nursing Facility Pay for Performance Program FY16 Bulletin. This form is available below.
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.
Yes. Any nursing facility may apply to the FY16 program even if it did not participate in FY14.
Yes. Any facility may apply to the FY16 program, even if the facility’s application was not accepted in FY14.
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.
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.
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.
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.
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
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.
To participate in this program, the committee must meet between October 1, 2015, and February 3, 2016, to discuss the P4P program.
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.
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
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.
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.
OLTSS anticipates that an audit will take between one and two hours.
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.
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.
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
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.
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.
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.
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.
All attestations must be submitted on or before 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.
Minutes from the committee’s meeting should include the following.
The committee should remove all notes on discussions about other items from the minutes if the minutes must be submitted to OLTSS.
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.
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:
Payments to qualifying facilities will be made by June 30, 2016.
The total FY16 budget for the NF P4P program is $2.8 million.
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.
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
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.