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Staffing Transparency in Post Acute Care Lines of Service

Written by: Darlene D'Altorio-Jones (1959-2015) on Saturday, August 15, 2015 Posted in: Inpatient Rehab

How will CMS tweak information gathered for Skilled Nursing Facilities (SNF),  should the SNF 2016 Proposed rule be upheld and how might this ruling affect other PAC providers in the continuous struggle to compare/contrast staffing hours based on service types across a continuum?

If you work in a SNF, most likely you read the recent proposed rule and recommended changes for SNF’s in 2016 reporting guidelines. As CMS aligns reporting requirements to meet the IMPACT ACT of 2014, will this type of reporting be the same for LTCH, IRF and SNF? Only time will tell.

Let’s become familiar with the proposal made by CMS for SNF 2016 and then look at what is presently reported and placed at the CMS SNF compare website in an attempt to provide transparency of information for persons deciding level of care.

More staffing better quality? Just how much correlation will new types of staffing data answer?

PROPOSED  Rule SNF Staffing Data Submission requirements:

    The facility must electronically submit to CMS complete and accurate direct-care staffing information, including the following:

  • The category of work for each individual that performs direct care (including, but not limited to, whether the individual is a registered nurse, licensed practical nurse, licensed vocational nurse, certified nursing assistant, therapist, or other type of medical personnel as specified by CMS);
  • (ii) Resident census data; and
  • (iii) Information on staff turnover and tenure, and on the hours of care provided by each category of staff per resident per day (including, but not limited to, start date, end date (as applicable), and hours worked for each individual).
  • Distinguishing employee from agency and contract staff. When reporting direct care staffing information for an individual, the facility must specify whether the individual is an employee of the facility, or is engaged by the facility under contract or through an agency.
  • Data format. The facility must submit direct care staffing information in the format specified by CMS.
  • Submission schedule. The facility must submit direct care staffing information on the schedule specified by CMS, but no less frequently then quarterly.

Presently, CMS provides similar information regarding staffing at their SNF compare website. However, the changes are in the definitions for how this information will be gathered.

Presently, each year close to the time of a SNF’s state annual survey, facilities must complete a form called CMS-671 and form CMS-672. These forms enable information on census (block 78 form 672), as well as two week staffing data specific to the time period (form 671). These forms establish the present ‘CASPER’ staffing data. CMS aligns MDS submission and case mix information (RUG utilization days) to define a case mix adjusted; 5 star rating system. You can read more about the 5 star system through the user’s guide updated in February 2015.

Presently, CMS utilizes this information to review RN hours and then ‘total’ staffing hours. As it is not specific to direct patient care at the moment, and contract hours are mingled in the totals, the newly proposed system will help to better define parameters and will separate contract from employee information. Also proposed is longevity information for years of service to the skilled facility.   CMS hopes to develop turnover data and will then begin to correlate a host of information against outcomes as it relates to staff compliments and consistency of care.


IF you are in post-acute care, you must pay attention to all proposed and final rules collectively in the PAC continuum. Why? Because defining care, outcomes and quality in a side by side comparison can only be accomplished when the IMPACT ACT of 2014 transparency is fulfilled and definitions are still formulating!  SNF CMS compare data site  is  blossoming with more and more information as it is gathered and no service line will be immune to transparency!   Will you be 5 star in staffing?

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