To qualify, a facility must:
- Possess 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 conduct status checks using the Provider Enrollment, Chain and Ownership System (PECOS); and
- Report to at least one of three data sources that establishes eligibility and collects provider data to inform payment: Certification and Survey Provider Enhanced Reports (CASPER), Nursing Home Compare (NHC), or Provider of Services (POS)
The incentive payment program will be divided into four monthly performance periods (September, October, November, December) with $500 million available to nursing homes each period. Facilities meeting the qualifications detailed above will be eligible for each of the performance periods. Nursing homes will be assessed based on a month of reported data, which will be subject to additional scrutiny and auditing by HHS before payments are issued the following month.
HHS will measure nursing homes against a baseline level of infection in the community where a given facility is located using data from the Centers for Disease Control and Prevention (CDC). CDC’s Community Profile Reports (CPRs) include county-level information on total confirmed and/or suspected COVID infections per capita, as well as information on COVID test positivity. Against this baseline, facilities will have their performance measured on two outcomes:
- COVID infection rates among residents; and
- COVID mortality among residents.
CMS issued guidance in May (WHG client summary) requiring nursing facilities to submit data to the National Healthcare Safety Network (NHSN) Long Term Care Facilities (LTCF) COVID-19 module. The incentive program will utilize data from the module to measure facility COVID infection and mortality rates, assess performance, and determine incentive payments.
Nursing homes will not need to apply to qualify for performance-based incentive payments and the payments will be subject to the same terms and conditions as the infection control payments.