OK SPA 22-0017 Nursing Facility Rebasing and Pay-for-Performance Update
For the rate period beginning July 1, 2022, a proposed amendment to the state plan and agency rules will recalculate the Quality of Care (QOC) fee for regular nursing facilities, nursing facilities serving residents with Acquired Immune Deficiency Syndrome (AIDS) and Regular and Acute Intermediate Care Facilities for Individuals with an Intellectual Disability (ICF/IID). Further proposed revisions to the Pay-for-Performance (PFP) language will improve facility accountability by requiring noncompliant facilities to forfeit PFP incentives for any quarter in which they receive a scope and severity tag deficiency of "I" or greater.
Please view the draft SPA pages here: OK SPA 22-0017, and submit feedback via the comment box below.
Tribal Consultation: 05/03/2022
60-day Tribal Consultation Period: 4/19/2022 – 6/18/ 2022
Circulation Date: 06/09/2022
Comment Due Date: 07/09/2022
Comments
Chad Mullen:
AARP, on behalf of our nearly 38 million members – including our nearly 400,000 members in Oklahoma – and all older Americans nationwide, appreciates the opportunity to provide comments on the Oklahoma State Plan Amendment 22-0017 Nursing Facility Rebasing and Pay-for-Performance Update.
AARP Oklahoma has long been engaged with the agency and elected officials to improve quality of care for some of our state’s most vulnerable individuals: nursing home and long-term care residents. AARP research (https://www.aarp.org/ppi/info-2018/state-long-term-services-supports.html) indicates that Oklahoma ranks among the worse in the nation in many measures of quality of care. In 2019 AARP Oklahoma, in partnership with others, worked to improve and secure passage of Senate Bill 280. Senate Bill 280, which among other things, revamped and improved the Pay-for-Performance (PFP) program to improve the quality-of-care for nursing home residents. Senate Bill 280 led to the creation of Oklahoma’s PFP program advisory committee of which AARP is a member.
The PFP program advisory committee has evaluated the effectiveness of the program and has identified areas of opportunity to better protect our loved ones from abuse, neglect and poor quality of care. The PFP program advisory committee identified one PFP provision which allowed a facility which received a survey scope and severity tag deficiency of “immediate jeopardy” or greater to remain eligible to continue to receive part of their quality bonus payment. This resulted in a perverse incentive that allowed a deficient facility to continue to receive quality bonus payments.
Oklahomans expect their loved ones to be properly cared for and they do not expect to have their taxpayer dollars support facilities who fail to meet quality standards. AARP supports incentivizing payments to providers based on actual improved quality outcomes which should include consumers’ reports of the quality of their care. AARP urges the agency to ensure that the PFP designs incentive rates in a manner that encourages and ensures quality care. We also urge the agency to enhance how state survey results and other information regarding quality, including comparisons with national standards when possible, are combined and made available to the public in an easily comprehensible online format.
We support the Oklahoma Health Care Authority (OHCA) decision to revise this provision to withhold the entire incentive for the quarter the facility was out of compliance. We believe, while limited in scope, this is an important first step to better aligning quality of care to funding. We believe this effort needs to be expanded and we stand ready to work with OHCA staff to further improve the quality of our long-term care residents.
OHCA Response:
Thank you for your ongoing support and input into the LTC Pay for Performance Program. We value the ongoing collaboration with AARP and the work in the PFP Advisory Committee.
