In a follow-up from our previous client alert the U.S. Department of Health and Human Services (HHS), posted details to the methodology for the $2 billion Provider Relief Fund “performance-based incentive” payment distribution to nursing homes.
Nursing homes will not have to apply to receive a share of this $2 billion incentive payment allocation; HHS will be measuring nursing home performance through required nursing home data submissions and distributing payments based on these data.
In order to qualify for payments under the incentive program, a facility must have an active state certification as a nursing home or skilled nursing facility (SNF) and receive reimbursement from the Centers for Medicare & Medicaid Services (CMS). HHS will administer quality checks on nursing home certification status through the Provider Enrollment, Chain and Ownership System (PECOS) to identify and remove facilities that have a terminated, expired, or revoked certification or enrollment. Facilities must also report to at least one of three data sources that will be used to establish eligibility and collect necessary provider data to inform payment: Certification and Survey Provider Enhanced Reports (CASPER), Nursing Home Compare (NHC), and Provider of Services (POS).
Performance and Payment Cycle
The incentive payment program is scheduled to be divided into four performance periods (September, October, November, December), lasting a month each with $500 million available to nursing homes in each period. All nursing homes or skilled nursing facilities meeting the previously noted qualifications will be eligible for each of the four performance periods. Nursing homes will be assessed based on a full month’s worth of the aforementioned data submissions, which will then undergo additional HHS scrutiny and auditing before payments are issued the following month, after the prior month’s performance period.
Using data from the Centers for Disease Control and Prevention (CDC), HHS will measure nursing homes against a baseline level of infection in the community where a given facility is located. CDC’s Community Profile Reports (CPRs) include county-level information on total confirmed and/or suspected COVID-19 infections per capita, as well as information on COVID-19 test positivity. Against this baseline, facilities will have their performance measured on two outcomes:
- Ability to keep new COVID infection rates low among residents.
- Ability to keep COVID mortality low among residents.
To measure facility COVID-19 infection and mortality rates, the incentive program will utilize data from the National Healthcare Safety Network (NHSN) LTCF COVID-19 module. Data from this module will be used to assess nursing home performance and determine incentive payments.