LeadingAge met on October 23 with representatives from the Centers for Medicare & Medicaid Services (CMS) Office of the Administrator and the Center for Clinical Standards and Quality including the Division of Nursing Homes to discuss nursing home survey and certification processes. LeadingAge inquired about recent changes to the State Performance Standards System (SPSS) and pressed CMS on timely annual release of findings. LeadingAge discussed a promising surveyor training model currently in use in one state that has improved surveyor – provider relations without compromising enforcement and urged CMS to learn more about this model and consider adopting this or a similar model as a federal requirement for surveyor training. Lastly, LeadingAge updated CMS on feedback from states and members about the Informal Dispute Resolution process and LeadingAge’s priorities for improvement.

LeadingAge sent a letter to the Centers for Medicare & Medicaid Services (CMS) on September 12 requesting a meeting to follow up on survey and certification reform. LeadingAge requested the opportunity to discuss the August release of the State Performance Standards System (SPSS) findings and a surveyor training model currently in use that is improving surveyor – provider relations in one state. LeadingAge will also update CMS on recent work around the Informal Dispute Resolution process. Read the letter here.

The Centers for Medicare & Medicaid Services (CMS) released State Performance Standards System (SPSS) findings for Fiscal Year 2023 on August 1. These annual standards review state survey agencies’ performance on a given set of metrics such as timeliness of various aspects of the survey process and survey quality. LeadingAge has used SPSS findings from past years to inform our work on nursing home survey reform. We will be addressing metrics related to recertification survey completion and frequency, assessment using Federal Monitoring Surveys, and informal dispute resolution in our continued work with CMS.

LeadingAge held a member call on July 25 to gather feedback on members’ experiences with the new Risk-Based Survey currently being piloted by the Centers for Medicare & Medicaid Services (CMS). According to information shared by the CMS, this survey model appears to align with LeadingAge’s recommendations for survey process reform by utilizing nursing home data and metrics to more effectively focus survey activities. Members who have experienced the Risk-Based Survey largely voiced support for the model, though a few opportunities for improvement were identified, which LeadingAge shared with CMS following the call. LeadingAge will continue to solicit feedback from members and provide information to CMS to advance this promising reform.

LeadingAge filed comments in the Federal Register on May 23 on the Fiscal Year 2025 Skilled Nursing Facility (SNF) Prospective Payment System (PPS) proposed rule. While the intent of the rule is to fulfill statutory obligations to announce payment updates for the coming fiscal year, the Centers for Medicare & Medicaid Services (CMS) often includes other provisions within these rules. This year’s proposed rule included a provision on nursing home enforcement and LeadingAge took this opportunity to urge CMS to reevaluate the survey process and consider our suggested reforms. Read the full comments here.

LeadingAge reached out to CMS to follow up on the April 30 meeting. LeadingAge provided CMS with background information on the LeadingAge survey and certification work plan and recirculated questions that LeadingAge had provided to CMS ahead of the April 30 meeting. LeadingAge inquired about the differences in survey and certification processes by CMS-certified setting, what work CMS is doing to improve citation and enforcement consistency and to hold state survey agencies accountable, what evidence CMS may have to show connections between increased citation and enforcement and quality improvement, and what impact CMS anticipates the new risk-based survey will have on citation and enforcement if implemented.

LeadingAge met with representatives from the Centers for Medicare & Medicaid Services (CMS) Office of the Administrator and the Center for Clinical Standards and Quality including the Division of Nursing Homes to discuss nursing home survey and certification processes. LeadingAge presented its survey and certification reform work plan, including common themes emerging from interviews with each of our state partners. LeadingAge priorities for reform include inconsistency in citation and enforcement, survey timelines, and system barriers to quality improvement.

LeadingAge sent a letter on March 28 to the Centers for Medicare & Medicaid Services (CMS) requesting a meeting to discuss nursing home survey and certification reform. LeadingAge briefly described recent work to identify areas of focus and invited CMS to engage in dialogue around what we have learned. Read the letter here.

LeadingAge sent a letter to the Centers for Medicare & Medicaid Services (CMS) regarding nursing home survey and certification reform. CMS disclosed on a December 2023 Open Door Forum its plans to pilot a new risk-based survey model in 2024. LeadingAge informed CMS that we will be addressing nursing home survey and certification processes in our work in 2024 and encouraged CMS to engage with us on the risk-based survey and other initiatives. Read the letter here.