Fall 2018

IN THIS ISSUE

Year 3 Monitoring of Facility Participation and Engagement

Upcoming Changes to Clinical Criteria and Documentation 

NY-RAH Project Group B Program Modification Underway 

Data Collection Responsibilities Rolled Out to Group B Facilities 

ECCPs Around the Nation 

Year 3 Monitoring of Facility Participation and Engagement

On October 24, NY-RAH entered Year 3 of Phase Two of the Nursing Facility Initiative (NFI). In 2017, at the start of Year 2 of Phase Two, NY-RAH informed facilities of its annual review process, including how it monitors facility engagement based on a set of minimum requirements outlined in the initial participation agreement. Multiple facilities that had no billed and paid claims for the first year of Phase Two were asked to either submit a minimum number of claims or withdraw from the project. As a result, two facilities were removed from the NY-RAH project at the end of Year 2. At the start of Year 3, NY-RAH again reviewed facility engagement and contacted facilities that did not bill or receive reimbursement for any claims within the past six months. Failure to actively engage in the project as demonstrated by submitting claims may result in the removal of additional facilities from the NY-RAH project.

Group A and Group B facility leadership should understand their responsibility to effectively engage in the NY-RAH project as part of this national initiative. Without each facility's continued commitment to active participation, the evaluation of the demonstration could hamper national efforts to ensure that nursing facilities are provided with the resources they need to care for long-stay residents. NY-RAH has continuously encouraged routine billing and the use of effective processes to support billing for the six qualifying conditions. Certain facilities have been asked to submit a required number of deliverables and specific documentation in order to continue participation within the project, or face a forceful withdrawal from the project.

The NY-RAH project management team (PMT) and other staff are committed to working with Group A and Group B nursing facilities to address any concerns about identification of changes of condition, payment workflow, processes, or submission of claims. The PMT will continue monthly monitoring of facility participation and compliance with Phase Two requirements and will contact those for which we identify any concerns and notice lack of meaningful engagement. If you have any questions, please contact Megan Burns, NY-RAH Associate Project Director.

Upcoming Changes to Clinical Criteria and Documentation

The CMS Nursing Facility Initiative (NFI), of which the NY-RAH project is a part, has specific clinical criteria and documentation requirements associated with the six qualifying conditions. The NY-RAH project has provided facilities and practitioners with resources for the clinical criteria associated with these six conditions. The NY-RAH project also shared its concerns about burdensome documentation and stringent criteria with CMS and requested that the agency review the criteria and documentation expectations and make appropriate changes.

NY-RAH is pleased to report that CMS is finalizing certain changes and revisions that will be shared with all participating Group A and Group B facilities and practitioners in early December via a CMS-hosted webinar. NY-RAH will share details of the webinar as soon as they are made available. In addition, all NY-RAH materials (i.e., PDF guidelines, pocket guides, chart audit tool) will be updated to reflect the revised criteria, which should not interfere with facility and practitioner billing, and should instead ease some of the burden.

For questions about the clinical criteria and documentation guidelines, please contact Faiza Haq, NY-RAH Project Manager.

NY-RAH Project Group B Program Modification Underway

The NY-RAH project underwent a significant program modification at the start of Year 3 of Phase Two (October 24, 2018). The modification resulted in the discontinuation of the Registered Nurse Care Coordinator (RNCC) role at Group B facilities. Effective with Year 3, Quality Improvement Specialists (QISs) will work with facility leadership to review resident information (e.g., transfers, admissions), workflows, and processes as they relate to the project and other QAPI interventions within the facility. Additionally, the project will add a new Clinical Project Specialist (CPS) position to help facilitate and promote increased practitioner engagement. 

Quality Improvement Specialist Staffing and Recruitment
To date, NY-RAH has filled eight of the 12 QIS positions (11 QISs and one Senior QIS) and is actively recruiting for the remaining positions. NY-RAH expects to fill all QIS positions by December 31, 2018. Until then, participating Group B facilities will receive support from the NY-RAH Clinical Director and the QISs that have already been hired via site visits. During these site visits, facility workflows are being reviewed and meetings with project liaisons are taking place. Once full staffing is achieved, each QIS will be assigned to work at two to three facilities.

Clinical Project Specialist Staffing and Recruitment
To date, NY-RAH has filled one of the six CPS positions and is actively recruiting for the remaining positions. Facilities should continue participation with the project as they have been without the CPS, as this is a new role that will supplement the current continuing interventions. 

Background on Group B Program Modification
At CMS's request, NY-RAH proposed a modification to the model for Group B facilities to reflect the evolving needs of the facilities. An updated staffing model was needed to extend and build on previous successes, as RNCC staff were not best suited to address the evolving needs of the facilities in order to achieve the goals of Phase Two. NY-RAH therefore proposed a staffing modification to help Group B facilities meet the goals of the Nursing Facility Initiative (NFI). CMS approved the modification over the summer, and implementation began shortly thereafter. 

Effective October 24, 2018, the RNCCs are no longer at Group B facilities, and each facility became responsible for all aspects of the NY-RAH project (i.e., identifying and tracking changes of condition, billing for eligible episodes, updating the data portal with resident information). The PMT prepared the facilities for the transition by requiring all facilities to 1) designate a NY-RAH Payment Liaison (NPL) to be responsible for identifying and tracking changes of condition, 2) submit a payment workflow that is sustainable beyond the RNCC, 3) assign data portal users to be responsible for entering resident information into the web-based portal, and 4) participate in the multiple trainings provided by the PMT on the transition and modification.

For any questions about the program modifications, please contact Megan Burns.

Data Collection Responsibilities Rolled Out to Group B Facilities

At the beginning of Year 3 of Phase Two, Group B facilities became responsible for collecting and entering all project data into the NY-RAH data portal (RNCCs handled this responsibility previously). The NY-RAH Data Analytics team provided facilities with trainings and resources to make the transition as seamless as possible. 

The Data Analytics team hosted an informational webinar with administrative staff to review overall data collection responsibilities. A separate webinar on the individual elements of the data portal was held for all new Group B facility data portal users who would be responsible for entering data into the portal. The webinars educated Group B facilities about the data collection process. Of note, while the RNCCs had handled data collection for Group B facilities since the project's start in 2012, Group A facilities have been responsible for entering data into the portal since the beginning of Phase Two in 2016.

The data team also shared a recording of the training webinar with all Group B facilities -- the recording will be shared with future data portal users or staff who require it -- and provided a Frequently Asked Questions (FAQ) guide and other resources to help data portal users understand what information must be entered into the various fields. Additionally, the data team has scheduled weekly office hours via a conference call every Tuesday at 11:00 a.m. -- all new and existing data portal users are encouraged to attend, as office hours are an opportunity to ask specific questions about challenges and share best practices amongst facilities.

For any questions about the data portal, including office hours, please contact Courtney Zyla, NY-RAH Data Analyst.

ECCPs Around the Nation

NY-RAH is one of six "enhanced care and coordination providers" (ECCPs) that received the Phase Two award for the CMS Initiative to Reduce Avoidable Hospitalizations among Nursing Facility Residents -- Payment Reform. ECCPs communicate monthly and meet annually to share best practices and learn from one another. NY-RAH highlights one ECCP each quarter to describe its unique features.

NYRAH_Summer2017_map

The Aging Institute of University of Pittsburgh Medical Center (UPMC), the University of Pittsburgh, and the Jewish Healthcare Foundation are collectively known as RAVEN (Reduce AVoidable hospitalizations using Evidence-based interventions for Nursing facilities in Pennsylvania). RAVEN's staffing model is a mix of nurse practitioners who provide hands-on clinical care and nurse educators who help train staff on communication of acute changes of condition, palliative care, and medication risks. In addition, RAVEN uses telemedicine to enhance around-the-clock communication among facility nursing staff, physicians, acute care clinicians, and nurse practitioners. Clinicians on the receiving end of telemedicine are employed by the ECCP. Eighteen nursing facilities participated in Phase One, 15 of which continued to Phase Two as Group B, with an additional 20 facilities in Group A.

For more information on the RAVEN ECCP, please visit: https://raven.upmc.com/.

      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.