LTC & Senior Living Best Practices & Insights Blog | OnShift

CMS' Comprehensive Care for Joint Replacement Model & Long-Term Care

Written by Peter Corless | Dec 9, 2015 7:04:00 AM

On November 16, the Centers for Medicare & Medicaid Services (CMS) released the final rule to implement a new Medicare Part A and B payment model called the Comprehensive Care for Joint Replacement (CJR), in which acute care hospitals in 67 defined Metropolitan Statistical Areas (MSAs) throughout the country will receive retrospective bundled payments for episodes of care for lower extremity joint replacement (LEJR) or reattachment of a lower extremity.

Under the model which goes into effect April 1, 2016, all related care within 90 days of hospital discharge from the joint replacement procedure will be included in the episode of care. CMS believes that this model will further its goals of improving the efficiency and quality of care for Medicare beneficiaries with these common medical procedures.

With this ruling, the hospital in which the hip or knee replacement procedure takes place will be accountable for the costs and quality of related care from the time of the surgery through 90 days after hospital discharge—what is called an “episode” of care. Depending on the hospital’s quality and cost performance during the episode, the hospital will either earn a financial reward or, beginning with the second performance year, be required to repay Medicare for a portion of the spending above an established target. This payment structure gives hospitals an incentive to work with physicians, home health agencies, skilled nursing facilities, and other providers to manage costs across providers and settings as well as make sure beneficiaries receive the coordinated care they need.

How does this impact Skilled Nursing Facilities in the 67 MSAs?

Hospitals will be setting up networks of post-acute care providers to partner with when patients are discharged from the hospital. They will want to partner with SNF’s who have demonstrated an ability to provide great care and outcomes and then discharge patients to a lower cost setting within a reasonable length of stay.

Medicare does not cover patients admitted to a SNF unless they have had a three-day stay in a hospital. Most patients undergoing the procedures covered by the CMS initiative are discharged from a hospital with less than a three-day stay. Therefore CMS has built into the model a three-day stay waiver ensuring patients will qualify for Medicare coverage for their rehabilitation stay at a SNF. However, in order for a SNF to qualify for the three-day stay waiver, the SNF must have had a Five-Star Quality Rating of THREE (3) or more stars for at least 7 of the previous 12 months.

According to a new analysis of CMS data from Modern Healthcare, that restriction could disqualify 1 in 3 SNFs in the joint replacement model’s 67 test locations from receiving the waiver! The analysis estimates that in some test areas, up to 80% of facilities would be barred from the waiver due to their low star rating.

What can you do if you’re currently a 1- or 2-star facility that will be disqualified?

The good news is that although the joint replacement bundled payment model goes into effect in April 2016, the three-day stay waiver for skilled nursing facilities won’t go into effect until the second year of the model. Therefore, there is still time to take action to improve your star rating. A facilities star rating is impacted by the three year survey history, staffing measures and quality measures. The need for a great next survey is a given. In addition, facilities can lose, maintain or add a star to their survey rating based on staffing and quality measure outcomes.

When it comes to the staffing star rating, you should know your current staffing star rating at all times. If your goal is to maintain your survey star rating, you need to maintain a 2- or 3-star staffing rating. If your goal is to add an overall star, you need to maintain at least a 4-star staffing level. You need to know where you stand every day such that if a survey team were to come into your facility today and do a two-week look back, you have 100% confidence that they will award you the staffing star rating that you want to achieve.

In addition, there are tools available to help you. OnShift provides detailed labor analytics and consultative support to help you understand your staffing star rating and the most cost effective way to meet your goals. You can learn more about OnShift Insight here or request a demonstration here.

Don’t wait, take action now to improve your star rating and ensure your facility will remain eligible to aid new patients in their recovery from LEJR procedures.