Category: Long Term Care Blog

Supplemental Health Care Services Agency Info

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As you may know, on August 28, 2022, Missouri Senate Bill (SB) 710 became law, giving the Department of Health and Senior Services (DHSS) the responsibility for the oversight of supplemental health care services agencies, including the registration and inspection process of such agencies and the investigation of complaints. DHSS has been accepting registration applications since October of 2023 and conducting unannounced inspections since October of 2024.

During the inspection process of a supplemental health care services agency, we inspect a sampling of temporary health care personnel files, contracts entered between the agency and health care facility, contracts entered between the agency the temporary health care personnel, and quarterly reporting surveys submitted by the agency. Please be aware of the below requirements of a supplemental health care services agency that our office inspects:

  • Pursuant to section 198.644. 1.(3) and (6), RSMo, each registered supplemental health care services agency is required, as a condition of registration, to meet the following criteria:
  • (3) Not restrict in any manner the employment opportunities of its health care personnel; and
  • (6) Refrain in any contract with any health care personnel or health care facility from requiring the payment of liquidated damages, employment fees, or other compensation should the health care personnel be hired as a permanent employee of a health care facility.
  • State regulation, 19 CSR 105.050, outlines the required documentation or information in health care personnel files reviewed during the inspections.
  • State regulation, 19 CSR 105.070, outlines the quarterly reporting requirements of the supplemental health care services agency that contracts with a health care facility that participates in Medicare or Medicaid.

For more information regarding the above requirements and our program, view the Missouri law and state regulations here: https://health.mo.gov/safety/shcsa/laws-and-regulation.html.

Please note that an individual or business who operates as a supplemental health care services agency without registering with the department is in direct violation of Missouri law. The registration status of an agency can be found on our public dashboard here: https://www.arcgis.com/apps/dashboards/06eee3aa727f4c4fa5e874590016ac5c.

If you have any questions or concerns, please contact Sally McKee, Regulatory Auditor Supervisor, by phone at (573) 291-8080 or email at sally.mckee@health.mo.gov.

Ombudsman Program Updates for Transfer and Discharge Notices

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Mid-America Regional Council (MARC) has changed their email address for transfer and discharge notices that are required to be sent to them. The new email address is tdlogombud@marc.org. MARC covers Platte, Clay, Ray, Jackson, and Cass Counties.

Crosslines Community Outreach (formerly Council of Churches of the Ozarks) has also changed their email address for transfer and discharge notices that are required to be sent to them. The new email address is ombudsmantransferdischarge@crosslines.org. Crosslines covers Barton, Jasper, Newton, McDonald, Dade, Lawrence, Barry, Polk, Greene, Christian, Stone, Taney, Dallas, Webster, Douglas, Ozark, Texas, Wright, Howell, Shannon, and Oregon Counties.

MDS Info – November 2025

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Payroll-Based Journal (PBJ) Submission Deadline Reminder

Nursing homes are required to electronically submit direct care staffing information to the Payroll-Based Journal (PBJ) system. Submissions must be received by the end of the 45th calendar day (11:59 PM Eastern Standard Time) after the last day in each fiscal quarter to be considered timely. PBJ data for 7/1/25 through 9/30/25 is due November 14, 2025. Please submit PBJ data as soon as possible to avoid delays.

 

SNF Quality Reporting Program (QRP) Submission Deadline Reminder

SNFs are required to report data to meet the SNF QRP requirements. The submission deadline for the SNF QRP is approaching. The following data must be submitted no later than 11:59 p.m. on November 17, 2025:

  • MDS data for 4/1/25 through 6/30/25;
  • NHSN data for COVID-19 Vaccination Coverage Among Healthcare Personnel for 4/1/25 through 6/30/25;

Swingtech sends informational messages to SNFs that are not meeting APU thresholds on a quarterly basis ahead of each submission deadlines. If you need to add or change the email addresses to which these messages are sent, please email QRPHelp@swingtech.com and be sure to include your facility name and CMS Certification Number (CCN) along with any requested email updates.

QIPMO RAI Process and MDS 3.0 Toolkit

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The QIPMO team is excited to announce that our full series of webinar recordings on the RAI process and MDS 3.0 is now complete and available for you and your team!

These sessions cover every chapter and key topic—from Care Planning (Chapter 4) to Medicaid Documentation and more—providing practical, easy-to-follow guidance to support your assessment and care planning practices.

You can watch all of the RAI Process and MDS 3.0 Webinar Recordings anytime.

We hope these resources help you strengthen your understanding, improve accuracy, and support quality resident care. Be sure to share them with your colleagues across your facility!

QSO-26-01-ALL REVISED: REVISED: Contingency Plans – State Survey & Certification Activities in the Event of Federal Government Shutdown

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QSO-26-01-ALL REVISED: REVISED: Contingency Plans – State Survey & Certification Activities in the Event of Federal Government Shutdown 10.31.2025

Memorandum Summary

Pursuant to the federal government shutdown, we are doing our utmost to:

  • Protect Medicare and Medicaid beneficiaries against immediate dangers to life and health, and
  • Prevent providers and suppliers from experiencing interruptions that would threaten their ability to provide healthcare services that are vital to Medicare and Medicaid beneficiaries.

In this memorandum we identify functions that (a) are not affected by a Federal shutdown, (b) excepted functions that are to be continued in the event of a shutdown (also referred to as “essential functions”), and (c) other activities that are directly affected, are not legally authorized to be performed, and therefore should not be operational during a Federal shutdown.

For full details, please see QSO-26-01-ALL REVISED: REVISED: Contingency Plans – State Survey & Certification Activities in the Event of Federal Government Shutdown.

New Missouri IDR Agency

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With over 50 years of experience in the Medicare/Medicaid space, in addition to recently being selected as the CMS Midwest QIO, Telligen is honored to be the new Missouri Informal Dispute Resolution (MO IDR) agency. While new to MO, the team performing the IDR work will remain in place, ensuring consistency in the process and partnerships.

Telligen is a trusted partner to U.S. government health agencies, state Medicaid agencies, self-funded employer and Taft-Hartley health plans, and managed care organizations, improving health outcomes for millions of people nationwide through proven health management solutions and healthcare expertise.

Contact information for the team, and general contact information for the project:

Carmen Woodward
cwoodward@telligen.com
Phone: 573-498-2801
Fax: 515-414-7657

Telligen MO IDR
1776 West Lakes Parkway
West Des Moines, IA 50266
MOIDR@telligen.com
Phone: 515-500-2532
Fax: 515-414-7657

Note: IDRs for certified facilities are not an excepted function and have not been authorized by CMS to be conducted during the federal shutdown.

Federal Shutdown

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The Centers for Medicaid and Medicare Services has issued a memo regarding the federal shutdown. Please read through the memo for full details as it describes certain activities that the Department of Health and Senior Services (or their contractors) currently does not have the authority to conduct – including revisits (unless certain circumstances apply), informal dispute resolutions, recertification surveys, and issuance of 2567s for citations that do not allege harm or greater.

https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/policy-memos/policy-memos-states-regions/contingency-plans-state-survey-certification-activities-event-federal-government-shutdown

Updated Versions of the Final MDS 3.0 Item Sets and Final MDS 3.0 RAI User’s Manual Now Available

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On September 23, 2025, CMS posted the final Minimum Data Set (MDS) 3.0 Item Sets version (v)1.20.1v4 which can be found in the Downloads section on the Minimum Data Set (MDS) 3.0 Resident Assessment Instrument (RAI) Manual page. This final version of the MDS v1.20.1 item sets (v4) will go into effect October 1, 2025.

On September 24, 2025, CMS posted an updated final MDS 3.0 RAI User’s Manual version (v)1.20.1 which can be found in the Downloads section on the Minimum Data Set (MDS) 3.0 Resident Assessment Instrument (RAI) Manual page. This final version of the MDS 3.0 RAI User’s Manual v1.20.1 will go into effect October 1, 2025.

DMH Free Webinars – Tools for Everyone

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Tools of Choice is an evidence-based program focused on the implementation of universal positive practices. This two-hour introductory training is open to community members, parents, and professionals. It covers key concepts of the Tools of Choice curriculum, including What is behavior, building positive relationships, and how to increase desirable behavior. Join the Positive Support Consultants in learning strategies to make positive change by implementing universal positive practices.

Registration is available on the DMH Webinars page.

Nursing Facility Level of Care (LOC) Process Changes

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In July 2025, the Department of Health and Senior Services Central Office Medical Review Unit (COMRU) and the Department of Mental Health (DMH) made changes to the processing of Pre-Admission Screening and Resident Review (PASRR) Level 1 applications that indicated a Level 2 evaluation should be completed. The goal of these changes was to streamline the process and to decrease the review time for these applications. This goal was accomplished, and applications are currently being reviewed by COMRU and sent to DMH within two working days of receipt.

To further enhance the efficiency of the process, effective October 1, 2025, Bock Associates, the DMH contractor that completes the Level 2 evaluation, will also begin conducting the level of care (LOC) on applications that indicate a Level 2 evaluation is needed. The LOC for these applications is currently conducted by COMRU following the Level 2 evaluation. In addition to further streamlining the process, this change will enhance the quality of the review as most of the Level 2 evaluations are conducted in person. In addition, any issues, questions, or corrections can be addressed immediately without the back-and-forth process that is currently in place. COMRU will work closely with DMH and Bock Associates to ensure a smooth transition.

COMRU will continue to conduct the LOC review for Level 1 applications, applications DMH determines “No Level 2 Required” (NL2R), applications Bock Associates determines did not meet the federal requirement, and Special Admission Category (SAC) applications. The change to the process will also improve the timeliness of these reviews.

This change will have no impact on the application or on the submission process.

 

Tips and Reminders

COMRU does receive several applications that do not indicate a Level 2 evaluation based on the responses on the application, however a review of the application and attachments/supporting documentation shows the application should have indicated a Level 2 evaluation. Often, the individual has already been admitted to a nursing home and payment to the nursing home may be delayed until the Level 2 evaluation is complete. A good refresher on the conditions that indicate a Level 2 evaluation can be found here. Please ensure a thorough review of the application and supporting documentation when making admission decisions. An additional tool that will aid in decision-making is a review of the information in CyberAccess. CyberAccess offers many services to providers, such as where Medicaid clients have been receiving services, billed diagnosis and much more. To register for CyberAccess, please contact 888-581-9797.

Section D – Level One Screening Criteria for Serious Mental Illness

  • Question 2 – Depression is often listed under this question, but it should not be included. A diagnosis of depression is different from a diagnosis of major depressive disorder.
  • Question 6 – Please review carefully to ensure this question is answered correctly. Incorrect answers will be returned for correction.

Section E – Level One Screening Criteria for Intellectual Disability or Related Condition

  • Question 2a – Thoroughly review all diagnoses listed, including those in purple text. In addition, diagnoses of traumatic subdural hemorrhage, traumatic subarachnoid hemorrhage and anoxic brain damage should be listed under head injury/traumatic brain injury (TBI). Please review carefully to ensure this question is answered correctly. Incorrect answers will be returned for correction.

Nursing Facility Level of Care Assessment

The LOC application is used across different settings, including approval for Home and Community based services. The application is an evaluation of the applicant’s current needs. Questions regarding Eating, Meal Preparation and Medication Management should be answered based on the applicant’s ability to complete these tasks, not on what services the nursing home provides. While residents of nursing homes do not normally prepare meals or manage their medications, the appropriate evaluation of these items is required. When answering these questions, it may be helpful to review the assistance needed in other areas, including other ADLs and the applicant’s cognitive status, to determine the most appropriate answer.

Section C – Recent Medical Incidents

  • All attachments must be in PDF format.
  • The applicant’s name must be listed on all attachments.
  • It is not necessary to list diagnoses if a diagnosis list is attached.
  • For Level 1 applications, it is not necessary to attach a H&P if the date and reason for hospitalization is explained in the comment section.
  • For Level 1 applications, the H&P should be limited to the date/reason for hospitalization. Applications that indicate a Level 2 require additional information.

Section D – Assessed Needs

  • Behavioral:
    • “Date of last consult…” is a psychiatric consult, if conducted. This should not be completed for a medical visit.
    • If behavior symptoms are checked, please review response – this would be either 3 (past) or 6 (current) points.
  • Mobility:
    • Describe the assistance required, rather than simply listing mode of locomotion. For example, do not just list wheelchair/walker.
  • Rehabilitative Services:
    • Scoring should be all frequencies added together.
  • Safety:
    • This question is a two-tiered evaluation. First, a preliminary score is determined based on vision impairment, fall history (within the last 90 days), and problems with balance. After the preliminary score is determined, additional points are given for prior institutionalization (within the last 5 years) and age of 75 years and over. No points are given for the current nursing home admission and the dates for the current admission should not be listed.

For additional information, including training opportunities, visit the COMRU Website.

Meet the Midwest QIN-QIO

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Please join us for a virtual event to meet the Midwest QIN-QIO.

This event will provide an overview of the CMS QIN-QIO 13th Scope of Work structure and highlight new components and differences from the previous SOW.

During this webinar, we will:

  • Review what we offer for providers and what participation means for them
  • Introduce key contacts at the Midwest QIN-QIO
  • Discuss how we can align efforts with existing and potential partner organizations and identify opportunities for collaboration

There will be time available for participants to ask questions and share information.

Partner with K-State: Are you ready to elevate resident voices?

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Are you ready to elevate resident voices? Join Kansas State University and the Moving Forward Coalition in piloting an innovative guidebook that prepares nursing home teams to better honor residents’ Goals, Preferences, and Priorities (GPP). After a successful launch in phase one, we’re ready for phase two beginning in October 2025 and seeking dedicated teams that are ready to make a difference!

Your team might be a good fit for this pilot project if…

  • You have a motivated team that is committed to furthering your person-centered care journey.
  • You have strong leadership in the home that values elevating the resident’s voice in all aspects of their daily lives
  • You are ready to invest time upfront for long-term sustainable improvements to your current systems
  • Your team enjoys collaborative work
  • You are able to commit to monthly meetings via Zoom to check-in with the program coordinator
  • You are excited to be part of research that will improve care in nursing homes nationwide

 What does this look like for you?

We’ve designed this pilot to work with your existing systems. Starting in October, you’ll partner with our Program Coordinator through monthly Zoom meetings alongside other homes in the pilot. You’ll receive two one-hour long trainings about important matters that can often be overlooked in long-term care.

Your team leads the way: identify improvement areas that matter to your team, create and work through action plans, and implement changes that fit your home’s unique needs. You’ll also gain access to proven tools and assessment examples from phase one participants.

Your team will work together to create a reasonable timeline for your action plans early on in the program. Implementation of new systems should start in January.

Are you ready to join us? Email Addie at afvanzut@ksu.edu with the name of your home, location, how many residents you serve and your home’s key contact person.

Have any questions? Email Addie at afvanzut@ksu.edu with questions or to set up a time to call.

NOW AVAILABLE: Final MDS 3.0 Item Sets version 1.20.1v3 and Final MDS 3.0 RAI User’s Manual version 1.20.1

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The final Minimum Data Set (MDS) 3.0 Item Sets version (v)1.20.1v3 and Item Matrix v1.20.1v3 are now available in the Downloads section on the Minimum Data Set (MDS) 3.0 Resident Assessment Instrument (RAI) Manual page. This final version of the MDS v1.20.1 item sets (v3) will go into effect October 1, 2025.

The final Minimum Data Set (MDS) 3.0 Resident Assessment Instrument (RAI) User’s Manual version (v)1.20.1 is now available in the Downloads section on the Minimum Data Set (MDS) 3.0 Resident Assessment Instrument (RAI) Manual page. The MDS 3.0 RAI User’s Manual v1.20.1 will be effective beginning October 1, 2025.

Nursing Home Reimbursement: Beginning to End

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The Family Support Division (FSD), Department of Health and Senior Services Central Office Medical Review Unit (DHSS COMRU), and the MO HealthNet Division (MHD) have collaborated to create a new resource for nursing facility providers. We are excited to announce, Nursing Home Reimbursement: Beginning to End.

This resource will walk a provider through the process of nursing home reimbursement from the very beginning of an individual applying for coverage, through the Preadmission Screening and Resident Review (PASRR) process, to billing and receiving payment for services. The resource includes step-by-step instructions for each process, definitions, contact information, and more.

For additional training opportunities, check out the below:

  • MHD offers an interactive webinar for nursing home providers quarterly. This training covers navigating MO HealthNet provider resources, proper billing methods, procedures for claim filing via eMOMED, and more. This training includes an opportunity to ask questions in real-time. Review the MHD Provider Training Calendar here.
  • COMRU PASRR and Level of Care (LOC) Orientation Training, hosted by COMRU, has a monthly orientation training to review the requirements of the PASRR and the Nursing Facility LOC application process.

For additional resources, refer to the Education and Training Resources page and/or sign up for a live webinar by accessing our Provider Training Calendar. For more information, email MHD.Education@dss.mo.gov.

Missouri Master Plan on Aging seeks final input from all Missourians

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The Department of Health and Senior Services (DHSS) and Missouri Area Agencies on Aging have published the draft of the Master Plan on Aging: Missourians Aging with Dignity and are seeking comments from the public before the plan is finalized. The comment period is open now through Sept. 15.

A Master Plan on Aging is a cross-sector, state-led strategic resource that can help transform the infrastructure and coordination of services for Missouri’s rapidly aging population. The plan helps build bridges across government agencies, facilitate collaboration with diverse stakeholders, promote equity, raise awareness among policymakers and the public, establish statewide priorities, and incorporate an aging and disability lens across state priorities beyond traditional health care and community.

There are currently more than 1.1 million Missourians over the age of 60. Estimates suggest that older adults will outnumber minors for the first time by 2030 and older adults will greatly outnumber minors by 2060, and the older adult population is also becoming more diverse. These demographic shifts will have a profound impact on the volume and types of services and support that states provide to older adults and people with disabilities, as well as family caregivers. Additionally, approximately 15 percent of the state’s residents have a disability, the most common of which is mobility disabilities. As the population ages, the number of individuals with disabilities is expected to increase.

Aging with Dignity: Missouri’s Master Plan on Aging is a 10-year forward-facing plan that will begin in 2026 and run through 2035. It was established by Governor Parson through executive order in January 2023. The following activities to gain community input have occurred since then:

  • An advisory council convened to guide the process of creating the plan. Seven subcommittees comprised of subject matter experts from diverse communities of practice and constituents met regularly to assess the resources and services currently available in the state, find areas of duplication or gaps in service, and determine possible areas for growth.
  • A series of town hall meetings throughout the state was held to gather feedback from local individuals who know about challenges in their own communities. These results were analyzed and provided to the advisory council, seven subcommittees and local agencies.
  • To gain further insight, the needs assessment was launched in 2024. The effort began with the mailing of over 130,000 postcards to randomly selected residents from all counties of the state. The survey was open to anyone in Missouri who wished to share their needs and wants as the State continued the process of developing the Master Plan on Aging.

“The amount of participation and support we have seen from Missourians across the state over the past two years has been inspiring,” said Mindy Ulstad, who leads the Bureau of Senior Programs within DHSS. “We feel confident that the plan, which is the result of an immense amount of collaboration and active listening, will encompass the needs and wants for all Missourians as we age.”

Community participation has been vital to the process of developing the Master Plan on Aging. Missourians are invited to provide feedback on the draft Master Plan on Aging by submitting comments by emailing MOStatePlanOnAging@health.mo.gov. The draft will be available for public comment until Sept. 15. After public comments, the final plan will be delivered to Governor Kehoe before the end of the calendar year.

The overarching goal of the Master Plan on Aging is that all Missourians, regardless of age or ability, will have access to person-centered programs and services necessary to help them age in their environment of choice in a safe and healthy manner. Learn more about Aging with Dignity.

Temporary Pause of Nursing Home Compare Updates

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CMS recently transitioned to a cloud-based Internet Quality Improvement and Evaluation System (iQIES) for nursing home survey and certification data. To ensure accuracy of publicly reported information during this transition, Nursing Home Care Compare updates will be temporarily paused as of July 30, 2025. Updates will resume in October 2025. This temporary pause allows CMS to ensure the accuracy and reliability of publicly reported nursing home quality information. QSSAM-25-03-NH

Skilled Nursing Facility Validation Program

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The SNF Validation Program is an audit-based program established to assess the accuracy of Minimum Data Set (MDS)-based quality measures used in the SNF Value Based Purchasing (VBP) and Quality Reporting Programs (QRPs). The SNF validation program audits are scheduled to begin in Fall 2025. SNFs selected for audit will be notified through their Internet Quality Improvement and Evaluation System (iQIES) MDS 3.0 Provider Preview Reports folder. The audit notification will contain instructions for documentation submission, the list of sampled residents for which medical charts are being requested and contact information for the contractor conducting the audit. For the FY2025 performance year/FY2027 program year, noncompliance may result in a 2% reduction of a SNF’s Annual Payment Update for the FY2027 SNF QRP program year.

CMS created a SNF Validation Program website which includes resources that can be found at SNF Validation Program.

CMS Memo Updates

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The Focused Infection Control (FIC) survey is retired as of 07-31-2025. Items in the downloads section on the Nursing Home webpage have been updated to align with the revisions to QSO-25-23-ALL.

According to CMS’ website, this also includes QSO 23-10- which contained the requirement for Enhanced Enforcement for Infection Control Deficiencies. EXPIRED: Strengthened Enhanced Enforcement for Infection Control

Additionally, CMS has posted on their website a revision/expiration of QSO-19-07-NH-Enhanced Oversight and Enforcement of Non-Improving Late Adopters/unnecessary psychotropics. EXPIRED: Enhanced Oversight and Enforcement of Non-Improving Late Adopters | CMS

All CMS QSO memos can be found at: Policy & Memos to States and CMS Locations | CMS.

Centers of Excellence for Behavioral Health – Grant Ending Sept 29, 2025

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DHSS has received official word from the Centers of Excellence for Behavioral Health that their grant will end on September 29, 2025. COE-BH is currently working on maintaining access to the site, including resources and trainings (without certificates) for 1 year post end of contract, however no consultations with Amber Jennings will be conducted after September 15, 2025. You are welcome to reach out to Amber until 9/15/25 for consultation at amber.jennings@allianthealth.org.

Payroll-Based Journal (PBJ) Submission Deadline Reminder

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Nursing homes are required to electronically submit direct care staffing information to the Payroll-Based Journal (PBJ) system. Submissions must be received by the end of the 45th calendar day (11:59 PM Eastern Standard Time) after the last day in each fiscal quarter to be considered timely. PBJ data for 4/1/25 through 6/30/25 is due August 14, 2025. Please submit PBJ data as soon as possible to avoid delays.

SNF Quality Reporting Program (QRP) Submission Deadline Reminder

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SNFs are required to report data to meet the SNF QRP requirements. The submission deadline for the SNF QRP is approaching. The following data must be submitted no later than 11:59 p.m. on August 18, 2025:

  • MDS data for 1/1/25 through 3/31/25;
  • NHSN data for COVID-19 Vaccination Coverage Among Healthcare Personnel for 1/1/25 through 3/31/25.

Swingtech sends informational messages to SNFs that are not meeting APU thresholds on a quarterly basis ahead of each submission deadlines. If you need to add or change the email addresses to which these messages are sent, please email QRPHelp@swingtech.com and be sure to include your facility name and CMS Certification Number (CCN) along with any requested email updates.