New Details on Incentive Payments for Nursing Facilities

On September 17, 2020, the U.S. Department of Health and Human Services (HHS) announced additional details regarding the $2 billion incentive payment structure for nursing facilities from HHS’s Provider Relief Fund (see section “How is the $2 billion incentive payment to skilled nursing facilities and nursing homes being determined?”).  In order for a nursing facility to be eligible for payment under this incentive payment distribution, it must pass two initial gateway tests:

• First, a facility must demonstrate a rate of COVID-19 infections that is below the rate of infection in the county in which the facility is located (Infection Measure).
• Second, a facility must have a COVID-19 death rate that falls below a nationally established performance threshold for mortality among nursing home residents infected with COVID-19 (Mortality Measure).

Infection Measure Calculation

For facilities that meet the gateway criteria, their COVID-19 infection performance will be measured by assessing two factors:

• The amount by which their own infection rate is lower than their county’s infection rate and total patient volume, as measured by resident-weeks.  In a given performance period, a facility’s infection rate will be measured as its total number of COVID-19 infections (not including COVID-19 admissions) divided by its total count of resident-weeks reported in NHSN.
• The difference between the facility’s and county’s infection rates is then scaled upward by the facility’s patient volume, as measured by resident-weeks, which yields the facility’s performance score on the infection measure. 

Mortality Measure Calculation

Facilities are eligible for evaluation of their COVID-19 mortality performance in a given performance period if they meet the gateway criteria and have at least one COVID-19 infection, other than COVID-19 admissions.  For these facilities, their mortality performance calculation will rely on two main pieces of information from NHSN data:

• The total number of COVID-19 deaths resulting from in-facility infections.
• The total number of non-admission infections.

These two pieces of information will be used to measure a preliminary COVID-19 mortality rate for each facility.  Direct outreach will be then be conducted to facilities that have at least one death in the performance period and have a mixture of COVID-19 admissions and in-facility infections to ascertain how many of their reported COVID-19 deaths were due to in-facility infections versus COVID-19 admissions.  These facility level characteristics will be incorporated with relevant health and demographic characteristics for each facility’s resident population into a statistical model that will be used to estimate the expected number of deaths for each facility in the performance period.  Facilities with lower mortality than expected will be eligible for payment, which will be scaled up based on the amount by which they fall below the expected number of deaths.

Incentive Payments

The tentative incentive payment dates by performance period, along with the tentative audit dates, are as follows:

For each performance period, the total available bonus payments will be based on aggregate performance on the infection measure. This total will then be split into separate payment pools for performance on the infection and mortality measures:

• 80% of bonus payments will be available to nursing facilities that have positive performance on the infection measure.
• 20% of bonus payments will be available to providers that have positive performance on the mortality measure.

 As more details become available  we will keep you informed.