Two New Quality Measures for Skilled Nursing Facilities
The Centers for Medicare and Medicaid Services (CMS) have adopted two new quality measures that will directly affect the discharge process for post-acute care settings (PAC) and skilled nursing facilities (SNF). The goal of the new quality measurements is to improve communication with patients and during provider-to-provider transfer. The ultimate aim is to improve patient outcomes by decreasing readmission rates and medication errors.
In 2013, 42% of all Medicare Fee-for-Service patients were discharged from an acute hospital setting to PAC, with 20% of those patients discharged to facilities offering skilled nursing care. Transferring patients between care settings poses significant risks and relies heavily on written, electronic, or verbal provider communication. Poor communication or incomplete health information will dramatically increase the risks of patient complications, medication errors, emergency department visits, hospital readmissions, and even death. In addition to adverse outcomes, poor communication of health information cost the United States health system between $25 to $45 billion in 2011. Residents of PACs and SNFs are most vulnerable to adverse events due to comorbid conditions, polypharmacy, and complex transitions between healthcare settings.
CMS has proposed two quality measures of healthcare to help reduce the risks of adverse events when transitioning between facilities.
The first measure, The Transfer of Health Information to the Provider, will determine if an updated medication reconciliation list is provided to the accepting healthcare personnel when a resident is transferred or discharged from his or her current Post-Acute Care Setting.
The proposed calculation for the Transfer of Health Information to the Provider:
number of current, reconciled medication lists provided to a subsequent provider at the time of discharge
total number of SNF resident stays discharged to a subsequent provider
The second metric, The Transfer of Health Information to the Patient, will assess whether a current medication reconciliation list is provided to the patient, caregiver, or family member when discharged from a post-acute care setting to a private residence or community settings such as a group home, assisted living facility, or hospice.
The proposed equation for Transfer of Health Information to the Patient:
total resident stays indicating a current medication reconciliation list was provided to the patient or their family
total number of SNF stays ending in discharge to a private residence or community setting
These core measures will evaluate the percentage of current medication reconciliation lists provided to the respective recipient while making an active attempt to reduce the incidence of medication errors and conflicting care plans, overall decreasing staggering healthcare costs.
Concerns to Proposed Rules
Several concerns were brought forward regarding the implementation of the proposed clinical quality measures. CMS staff responded to each of the questions posed with a rebuttal.
A significant concern with commenters was that collecting and reporting this data would cause added burden to facility staff and reap little benefit, citing that not all healthcare facilities have electronic medical records, hindering those facilities from electronically submitting the information. CMS responded by noting that the agency is mindful of the healthcare personnel burden and stressed that each measurement is only one data point, which aligns with existing transfer requirements that were put in place to ensure the safety of the patient.
Multiple commenters stated the CMS rules were vague because they did not specify how medication lists needed to be delivered. Additional commenters agreed and requested CMS to clarify the documentation expectations and select the least burdensome method to comply. CMS responded by stating that the methods in which to provide the medication list should be left up to the discretion of the provider and provided a guideline on what should be included in the medication list, such as the medication name, route, dose, and when to resume certain medications. It was again emphasized that these measures were proposed for an overall quality improvement in healthcare.
Preparing For These New Quality Measures
The new quality measures are proposed to begin on October 1, 2022. Administrators should prepare for the upcoming change now by evaluating the best method to report the required metrics to CMS and by educating leadership staff on the upcoming changes to the current requirements. Administrators may also need to review the medication reconciliation handoff process in their facility to ensure they maintain optimal results for these new quality measures.