CMS Holds Initiative-Wide Learning Community

NY–RAH Conducts Chart Reviews, Shares Best Practices

NY–RAH Releases Facility Payment Chart Audit Tool

NY–RAH Phase Two Year One Administrator Survey Results

ECCPs Around the Nation

CMS Holds Initiative-Wide Learning Community

On January 24, the CMS project officers from the Nursing Facility Initiative (NFI) held a learning community webinar for the six participating projects across the country, including facility leadership and practitioner staff. This was the first opportunity CMS has provided to facilities and practitioners to hear directly from CMS and ask questions related to the Initiative.

During the webinar, Evan Shulman, former NFI Project Director and current Deputy Director of CMS's Division of Nursing Homes, Quality and Safety Oversight Group, detailed the reasons for implementing Phase Two of NFI, including how existing payment policies could inhibit the effectiveness of nursing facilities' clinical interventions. Having reviewed several types of payment reforms for Phase Two, CMS elected to create payment incentives for six conditions (CHF, COPD/Asthma, Pneumonia, Cellulitis, Dehydration, UTI), which account for 83% of avoidable hospitalizations and can be managed in nursing facilities. CMS reviewed literature, cross-referenced existing payment sources, and convened a panel of technical experts to develop the qualifying criteria, treatment intensity, and duration for the six conditions.

Findings from the Phase One evaluation have since been converted into standard CMS policy, and were incorporated into the updated Requirements of Participation for Long Term Care (LTC) Facilities, State Operations Manual, and LTC Survey Pathways. Specifically, the new requirements address how changes in a resident's condition are communicated and if a structured tool is used (e.g., INTERACT); the facility's ability to adequately identify and address changes of condition; and whether a hospitalization is necessary.

Based on the event's success, CMS intends to hold more learning communities for all project participants. NY-RAH will alert facility leadership and eligible practitioners about upcoming events.

NY-RAH Conducts Chart Reviews, Shares Best Practices

In recent months, NY-RAH staff visited multiple Group A and B facility sites to review charts associated with facility and practitioner payment incentives. The goal of the effort was to compile information to be shared with all 58 participating nursing facilities and eligible practitioners. Also, discrepancies, misconceptions, and errors found during the visits were used to develop a presentation for participating NY-RAH facilities. On January 31, NY-RAH hosted a combined Group A and B Clinical Intervention Learning Community webinar to discuss lessons learned, documentation and billing clarifications, and best practices. The webinar helped prepare facilities for upcoming sites visits by Telligen, CMS's operations support contractor. Telligen will visit all NY-RAH facilities to audit charts during Phase Two. Facilities and practitioners unable to participate are strongly encouraged to review the recording of the webinar, available here.

NY-RAH Releases Facility Payment Chart Audit Tool

To help facilities prepare for Telligen's site visits and chart audits, and ensure that all claims billed under the facility payment incentive codes are compliant with CMS's clinical criteria, NY-RAH created an Excel-based chart audit tool . Facilities can use the tool to determine whether an episode should have been billed for, or should be billed for. To use the tool, facilities input (a) resident information, (b) dates for the episode, documentation, and billing, and (c) which criteria the resident met to qualify for the condition. The tool uses built-in logic to provide instant feedback and/or error messages based on the information entered. Facilities are encouraged to use the tool on a sample of charts previously billed under G9679 through G9684, and prospectively on all charts prior to billing for an episode. Facilities should share found discrepancies within their NY-RAH project workgroup to promote greater compliance. NY-RAH encourages facilities to provide feedback to improve the tool's efficacy.

If you have questions or feedback about the chart audit tool, please contact Faiza Haq, NY-RAH Project Manager for Payment Reform, at or (212) 506-5421.

NY-RAH Phase Two Year One Administrator Survey Results

Last November, NY-RAH administered a Phase Two Year One survey for administrators of the 58 participating facilities. Its purpose was to quantify how each facility's billing and reimbursement, project workgroups, and data and reporting processes were impacted by Phase Two's facility payment incentives and project interventions. Fifty-seven facilities completed the survey, which is indicative of each facility's engagement with the project. The survey results highlighted several key factors that help facilities engage practitioners and monitor the use of payment incentives to maximize billing opportunities.

At the start of Phase Two, NY-RAH encouraged each facility to establish a workgroup to monitor and evaluate its performance as related to facility payment incentives. Almost all respondents (91%) stated that their facility has a group that meets regularly to discuss the facility's progress with NY-RAH (NY-RAH workgroup). The overwhelming majority of respondents with a NY-RAH workgroup (98%) revealed that their workgroup meets at least once a quarter, and nearly half of respondents (46%) noted workgroup meetings occur at least once per month. While NY-RAH workgroup activities vary, 56% of respondents' revealed that missed opportunities for billing new facility incentive payment codes are regularly discussed at workgroup meetings. NY-RAH encourages facilities to review their eligible residents' conditions to identify potential missed opportunities. This is a good process improvement exercise that will positively impact facilities moving forward in Phase Two.

NY-RAH appreciates each facility that shared information about its Phase Two internal processes. Survey responses will inform much of the Year Two programming. Next month, NY-RAH will compare your facility's responses to select questions against responses from the other 56 facilities to provide additional insight on how your facility fares in specific areas compared to the rest of the group.

ECCPs Around the Nation

NY-RAH is one of seven "Enhanced Care Coordination Providers" (ECCPs) that received the Phase One award for the CMS Initiative to Reduce Avoidable Hospitalizations among Nursing Facility Residents. The ECCPs across the Initiative meet annually and speak monthly to learn best practices from each other. Six of the seven ECCPs continued to Phase Two and have worked together to develop educational and promotional materials for facilities and practitioners. NY-RAH will highlight an ECCP each quarter and describe its unique features and best practices.


The Sinclair School of Nursing of the University of Missouri's project is known as the Missouri Quality Initiative for Nursing Homes (MOQI). In Phase One, MOQI placed advanced practice registered nurses in 16 participating nursing facilities in the St. Louis area to provide hands-on care, help staff improve the early recognition and management of illness in addition to registered nurses that coach staff on how to use INTERACT tools. MOQI also set quarterly target transfer rates for participating nursing facilities. MOQI, like NY-RAH, also incorporated an electronic health information exchange system called CareMail, with transfer hospitals through the Missouri Health Connection, Missouri's official statewide health information network.

For Phase Two, MOQI continued partnering with the 16 Phase One nursing facilities (Group B) and 24 new nursing facilities (Group A) to continue testing the Phase One clinical interventions, plus payment incentives in Group B, and payment incentives alone in Group A. MOQI continues to set quarterly target transfer rates for Group B facilities and also provides Group B facilities with billing feedback reports. While the reports are provided to Group B facilities only, Group A facilities can access the data and use it to create their own reports.

For more information on the MOQI ECCP, please visit

      NY-RAH is supported by Funding Opportunity Number 1E1CMS331492-01-01 from the US
Department of Health and Human Services, Centers for Medicare & Medicaid Services. The
contents provided are solely the responsibility of the authors and do not necessarily represent
the official views of HHS or any of its agencies.