** I'd like to welcome Jen Farley, Carole Schwartz, and Ann Spenard who will be responding
to the questions submitted over the last two days **
So there is one general question before we jump into the sections.
Regarding the entire assessment tool, I know regarding the entire -- regarding the IMPACT
Act law, the data points promote interoperability.
However, many of the LTCHs are paper-based.
Any future plans to allow the QIES system to be queried?
Let the users see if the person had the flu vaccine at another location?
Thank you.
And the response for that is that there are no current plans at this time to allow the
QIES system to be queried.
However, typically post-acute care providers obtain flu vaccination and any other information
at the time of care transition from the care setting for which the patient is coming from.
Now we have the first section, Section A, administrative info question.
If the discharge location is a skilled nursing unit or nursing home and that was the intention,
it was intended to be the final destination and the patient returns within three days,
is it a program interruption or a separate stay?
So in this scenario, if the intent was that the patient was being discharged from the
LTCH to the skilled nursing unit or a nursing home, and the patient returned to the LTCH
within three days, this would be a considered a discharge.
You would also complete a new Admission Assessment for the date the patient returned to the LTCH.
And that's important because there was an intention that this was the patient's discharge
and final location.
So not to confuse it with the program interruption.
Section A, Administrative Information question number two.
It was mention that the dash should be used only as appropriate.
But it is expected to be a rare occurrence and that overuse may result in a 2% payment
penalty.
How do we quantify "rare" in this instance?
Or what is the threshold before that penalty would be applied?
So hopefully after my last presentation you guys have a better sense of that.
But CMS is aware that there are circumstances in which LTCHs may not be able to complete
every item on the LTCH CARE Data Set assessment, for example, for patients admitted to and
discharged from the LTCH on the same day.
For the purposes of the LTCH QRP, the 2% annual payment update penalty is related to the completeness
of data submission for the quality measures.
LTCHs must meet or exceed two separate data completeness thresholds, one threshold set
at 80% for completion of quality measure data collection using the LTCH CARE Data Set submitted
through the QIES ASAP system, and the second threshold at 100% for quality measure data
collected and submitted using CDC/NHSN.
For more information on verifying data submitted to CMS and threshold calculations, we refer
you to the LTCH QRP Quick Reference Guide, which is available for download on the LTCH
quality reporting submission deadlines website, which we actually just reviewed.
The next question for A, why is single not listed as an option under marital status field?
Since we would like the categories to be mutually exclusive, please choose the answer that best
describes the current marital status of the patient for item A1200.
In other words we don't want a person in one group to also be categorized in another group.
For example, if a patient has never been married and is currently single, code 1, never been
married.
Another example is if a patient was divorced and is currently single, code 5, divorced.
Next Section A question.
How should a provider complete the item requesting a Medicare ID number if the patient is not
a Medicare beneficiary?
This was a question from earlier as well.
If the person is not a Medicare beneficiary and does not have a Medicare number, or a
comparable railroad insurance number, this item should be left blank.
And in a related question for patients that do not have Medicare or Medicaid benefits
and instead have commercial or managed care benefit, is the Social Security Number still
required on these patients?
The Social Security Number should be completed for patients who do not have Medicare or Medicaid
benefits.
To avoid inaccuracies in patient record matching, A0600 should be left blank if the patient
does not have a Social Security Number, or in rare instances where the Social Security
Number is unavailable.
If the patient does not have a Social Security Number, or the Social Security Number is unavailable,
then the item maybe left blank.
Next Section A question regarding the Medicare beneficiary number, what about patients who
are not Medicare?
A second question regarding -- this has two parts to it.
And then a second question regarding race.
It would be helpful to have another option that people could choose from for people that
identify with multiple racial ethnicities.
So the first piece about if the patient is not a Medicare beneficiary, does haven't a
Medicare beneficiary number.
Information for patients who are not on Medicare can be found on the following CMS website.
So there's a reference site in the link.
So these FAQs will be posted and you can reference the link right there and get all of the detailed
information about other payers, so non-Medicare payers and how to handle them.
Regarding the second question, the race/ethnicity codes use the common uniform language approved
by the Office of Management and Budget to report racial and ethnic categories.
The guidance provided in Chapter 3, Section A of the LTCH QRP Manual explains that in
coding this section, the provider should ask the patient to select the category or categories
that most closely correspond with his or her race/ethnicity from the items in A1000.
You can also offer the option of selecting one or more racial designations.
If the patient chooses to not provide an answer it is allowable to use a dash for this item.
The next question is related to Section O actually, the influenza vaccination.
If a healthcare worker vaccinations are below national average, is that a potential penalty
for facilities?
There is currently no penalty for facilities if the healthcare worker vaccinations are
below national average.
The LTCH QRP is a pay-for-reporting program, and for purposes of the LTCH QRP, the 2% annual
payment update penalty is not tied to performance on quality measures, but rather completeness
of data submission for the quality measures.
Compliance determinations are based on whether or not the LTCH reports the required quality
measures data to CMS.
Okay.
A couple more.
The next one is also an influenza question.
Patient received influenza vaccine in September while in acute care hospital, admitted to
the LTCH in October.
How is O0250C coded since the vaccine was received outside of the LTCH facility and
not during the immunization vaccination period.
For item O0250C, code 2, received outside of this facility, since you assessed the patient
for the influenza vaccination during the influenza vaccination season, and the patient received
the influenza vaccine outside of your LTCH during the influenza season.
The next question is for the CAM.
How is a day defined?
Does it include a 24-hour day?
That was a question from the room.
It is correct, that it is considered a 24-hour day for the CAM assessment.
And next I'll turn it over to Carole for the Section GG.
**** Thanks, Jen.
So we received some questions about Section GG.
And the first question we'll be responding to is, if walking was Not Applicable prior
to illness and patient was pushed in wheelchair, should 9 be reported for GG0100, or 1, Dependent?
Both were mentioned during the instruction.
Our response is, GG0100 prior functioning indoor mobility ambulation is coded as 09,
Not Applicable, as the patient did not ambulate prior to the current illness, exacerbation
or injury.
The second question we'll respond to is indoor mobility ambulation.
In the past we have coded just for ambulation not wheelchair mobility because ambulation
is walking.
You spoke of coding for mobility and referred to ambulation, a wheelchair, but clearly states
ambulation, what is CMS's intent here?
You are correct that the item GG0100 only pertains to indoor mobility ambulation and
does not consider mobility via wheelchair.
Whereas specified GG0170 mobility items do include either ambulation or wheelchair mobility.
The next question we'll address from Section GG is what defines "poor quality" as it relates
to GG0130 and GG0170?
For instance, if a patient can feed themselves without assistance but results with food on
face or clothes et cetera, how would GG0130A be coded?
Are there other examples you could provide to clarify what is meant by "poor quality?"
For the Section GG items, GG0130 self-care and GG0170 mobility, clinical judgment is
used to determine if a patient's performance for an activity is considered to be of poor
quality, such that helper assistance is required.
This determination for helper assistance is based upon patient safety and completion of
the activity.
If the quality of the patient's performance is considered poor due to unsafe, then assistance
-- or due to safety -- then assistance is provided to safely complete the activity.
If the patient's performance appears to be inadequate based upon the intent of the activity,
for example, for eating, if the patient's poor quality performance is due to let's say
hand tremors, and much of the food content from the eating utensil drops rather than
being placed into his or her mouth, then the helper would provide steadying assistance
needed to complete the activity for eating.
The last question for Section GG that we'll answer is, we do not understand fully why
an LTCH is not expected to use code 10.
Please explain further.
Because it is -- our response is, because this is a standardized cross-setting measure
that includes the use of cross-setting codes, we have included all coding that will appear
in the PAC QRP assessments for Section GG.
As stated, the newly added Code 10, Not attempted due to environmental limitations, is not expected
to be applicable for the LTCH CARE Data Set items.
The LTCH CARE Data Set includes a subset of all Section GG items.
The IRF-PAI does include Section GG items where code 10 could be applicable.
For example, the IRF-PAI Section GG includes a car transfer item.
If the IRF in this case can not assess the patient for car transfer performance due to
weather or not having access to an indoor car or car simulator, then the IRF would use
Code 10, Not attempted due to environmental limitations for the IRF-PAI QRP item car transfer.
So I will pass the baton here to Ann.
**** Thank you.
We just have a couple more questions and then we'll be done.
So, Section M, Skin.
If upon admission there was not a wound assessment completed within a 3-day period, and was coded
a dash incomplete, dash or incomplete, at discharge if a wound was documented on day
4 with a discharge present on admission field be completed with a dash unknown or not present
on admission?
And the answer to that is, if a wound assessment was not completed within the 3-day period,
and was coded as a dash and then on day 4, for example, a Stage 2 pressure ulcer injury
was identified, at discharge if the Stage 2 pressure ulcer injury is present, you would
code M0300B1 under the Admission Assessment with a dash.
And M0300B1 discharge as 1.
Because they had one Stage 2 pressure ulcer at discharge.
And then M0300B2 that asks for the number of these Stage 2 pressure ulcers that were
present upon admission as a dash.
Because you didn't assess at admission.
The second question we have is, please clarify non-removable.
If a wound vac non-removable -- is a wound vac non-removable?
If it is not due to be, they said discharge, but I think they meant discontinued, is an
order required to validate that a dressing can not be removed?
So the answer is, a wound vac could be considered non-removable if there is a order to not remove
it during the assessment period and there is a known pressure ulcer injury under that
dressing.
If there is a dressing or device with an order to not remove until a particular time outside
of the 3-day assessment period, this also would be considered a non-removable dressing
if it had a known ulcer.
In the absence of a specific order to not remove a dressing or device, facility policy
should be followed.
And that is the end of our questions.
And these will be posted.
Mark is coming up.
**** Are there any burning questions you'd like to ask from one of the microphones?
In that case, just a few -- I'm sorry.
We have one.
**** I'm Theresa Hayes.
I work with L-track.
We're an outcome data system for LTCHs.
And just wondering could you go back to the -- I think the very first question about the
program interruptions from Section A. Could you just -- I'm just asking if you could go
back to the first question, the program inter-- the patient goes to a skilled nursing facility.
Could you just repeat that.
I just wanted to make sure -- Thank you.
**** So the question Theresa was asking to go through again is, if the discharge location
is a skilled nursing unit or nursing home and it was intended to be the final destination,
but the patient ends up returning within 3 days, is it a program interruption or a separate stay?
And so in this case, the intent was that the patient was being discharged.
It wasn't like an acute transfer and we're expecting that they might come back.
So in this case, the patient would be considered to be discharged from the facility and then
upon return they would have a new Admission Assessment completed.
So although it's inside of the 3-day range, we're making that distinction that there was
intent that they were discharged and to remain out in the skilled nursing facility.
**** Thank you for the question.
**** Hello I'm Sherry Lock with Cornerstone Healthcare Group.
I'm just curious on the Drug Regimen Review that is required at admission.
How come it's not required at discharge?
Because that's such an important part of the transition of care.
**** Thank you for the opportunity to respond to that question.
So the Drug Regimen Review N2005 includes upon admission through discharge.
So in fact, discharge would be included.
So it is a comprehensive item that includes anytime during or upon admission throughout
the stay.
And discharge is considered up to that point.
Does that answer your question?
Great.
**** Thank you.
So everyone who registered and attended in person will receive a certificate via email.
All of the sessions from both days will be uploaded to the CMS YouTube site.
The materials and the question and answer will be posted to the LTCH QRP webpage.
And we will email all of the attendees as these materials become available, and you
may receive announcements from CMS as well.
So I just need to now thank CMS.
Thank my colleagues and staff that have put the training together.
Thank the faculty for their presentations.
And most importantly, thank all of you for your time and attention and for the care that
you provide to LTCH patients every day.
This concludes the LTCH QRP Provider Training.