The federal government this week opened a public comment period on a proposed new quality metric that would measure each nursing home’s ability to curb the spread of infections.
The Skilled Nursing Facility (SNF) Healthcare-Associated Infections (HAIs) Requiring Hospitalizations measure would track the rate of nursing home stays that result in acquired infections — specifically by tracking the principal diagnosis on each nursing home resident’s Medicare hospital claims during a window that stretches from the fourth day of the SNF stay to the third day after a nursing home discharge.
The metric would be risk-adjusted based on a complex formula, with the Centers for Medicare & Medicaid Services (CMS) acknowledging that some amount of acquired infections is always likely in the post-acute setting.
“It is important to recognize that HAIs in SNFs are not considered ‘never-events,'” CMS noted in its draft description of the measure specifications. “The goal of this risk-adjusted measure is to identify SNFs that have notably higher rates of HAIs that are acquired during SNF care and result in hospitalization, when compared to their peers.”
The development of the proposed metric came as part of the larger CMS Meaningful Measures framework, a 2017 initiative that the current administration pitched as a way to streamline compliance by focusing on a narrower range of measures that more accurately illustrate provider quality.
But scrutiny of infection control practices in nursing homes has snowballed in the wake of COVID-19’s impact on nursing facilities, with resident advocates criticizing the federal government for its perceived leniency in issuing fines related to infection deficiencies.
For CMS’s part, the agency has boosted financial penalties for facilities with histories of infection control problems to up to $20,000 per instance in some cases, and last month touted its issuance of $15 million in civil monetary penalties (CMPs) since the start of the coronavirus pandemic.
Even before COVID-19 ripped through long-term care facilities, infection control was a long-standing issue for providers across the country — a problem that CMS insists can be remedied.
“Most HAIs are considered potentially preventable because they are outcomes of care related to processes or structures of care. In other words, these infections typically result from inadequate management of patients following a medical intervention, such as surgery or device implantation, or poor adherence to hygiene protocol and antibiotic stewardship guidelines,” the agency noted in the draft. “Measuring HAIs among SNF residents can therefore provide valuable information about SNFs’ quality of care.”
For the purposes of the proposed metric, a HAI would consist of
“infections that are likely to be contracted during SNF care,” such as an antibiotic-resistant staph infection, or infections associated with medical devices such as catheters, insulin pumps, tracheostomy stomas, and central lines.
The metric would have a host of exceptions, such as chronic infections like hepatitis B, infections associated with prior hospital says, and certain community-acquired infections.
While CMS admitted that such a metric could have unintended consequences — such as incentivizing SNFs to select for specific types of residents, or encourage shorter stays — the agency noted that the risk adjustments should help mitigate the potential for provider behavior changes.
“This measure will provide valuable information regarding SNF quality of care to consumers and allow SNF providers to track and improve their performance in this measure area,” CMS concluded.
CMS contracted with third-party policy research firm Acumen to develop the new metric. The comment period, which opened Monday, will extend through October 14.