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5 measurable quality initiatives form core of CMS Action Plan

September 12, 2012
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CMS recently issued its 2012 Action Plan for Further Improvement of Nursing Home Quality. The Action Plan, which was distributed to state survey agency directors, highlights the continued movement by CMS toward empirically based healthcare and outcome management. As nursing homes compete in the post-reform environment for new direct patient admissions and more hospital discharges, several data-driven tools—from Five Star rankings to hospital readmission benchmarks—that form the core of CMS’ focus on quality will be critical to nursing homes’ success. The Action Plan details CMS’ efforts to continue to improve nursing home safety and quality, organized into the following five actionable strategies:

  1. Enhance consumer engagement
  2. Strengthen survey processes, standards and enforcement
  3. Promote quality improvement
  4. Create strategic approaches through partnerships
  5. Advancing quality through innovation and demonstration

Several key aspects of each of these action items—many of which have already been implemented—are discussed in more detail below.


As part of its continued efforts to involve individuals as active and informed participants in their care, CMS has redesigned the Nursing Home Compare website to make it easier to use and understand. Seven quality measures derived from MDS 3.0 data will be added to the website. Additionally, CMS will evaluate other quality measures for inclusion on the website, focusing particularly on measures of hospitalization, discharge to community and functional status improvement. CMS will also post on the Nursing Home Compare website nursing home staffing data taken from payroll reporting, and CMS will develop a prototype system for the collection of payroll-based staffing data. Utilizing the new transparency reporting requirements under the Affordable Care Act, CMS has posted nursing home ownership information as well. For a summary of the redesigns that have already been implemented this year, see CMS’ July 19, 2012 notice.


CMS is planning several initiatives to improve the effectiveness of annual nursing home surveys and complaint investigations. The State Operations Manual and the Interpretive Guidance to Surveyors for Long Term Care Facilities continue to be revised. In 2012, new guidance will be released for feeding tubes, end of life and advance directive tags. 

To address a one percent decrease in the percentage of surveys being completed under the State Performance Standards System during 2010 and 2011, CMS is generating a quarterly report on performance to help regional offices identify states that are in the early stages of falling behind on the completion of surveys, so that early interventions can be initiated.

Also, in the winter of 2012, CMS plans to publish final guidance regarding the collection of civil money penalties prior to appeal. In that same timeframe, CMS will conduct a data analysis of the frequency and amounts of penalties to determine trends and outliers.


Jason Bring


Jason E. Bring, Esq., is a member of the Healthcare Group of...