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January Thaw: Get Ready for the QM Unfreeze

Although spring may seem like a mirage right now, it’s time for nurse assessment coordinators (NACs) to prepare for a literal thaw in the Five-Star Quality Rating System. As of January 2025, the Care Compare refresh will unfreeze four Quality Measures (QMs), frozen since April 2024 following the change from section G to section GG on Oct. 1, 2023. The transition impacted all four of these measures so substantially that the data is incomparable. And the Centers for Medicare & Medicaid Services (CMS) didn’t just shift from G to GG. Names of the measures, updated specifications, and one entire measure were entirely changed. This article reviews the history of the freeze, details the modifications to the affected measures, and describes what facilities can expect in January.

A Cold, Dark History

Many NACs felt left in the dark about how to manage quality improvement when CMS simultaneously announced the freeze and the update of four measures used in the Five-Star QM domain. Section G and GG data were clearly incompatible, but additional changes were not fully explained, such as removing the high-risk stratification of the pressure ulcer measure and no longer including residents who locomote in a wheelchair in the measure of being able to move independently. Publicly reported scores for these measures described outcomes from Oct. 1, 2022, to Sept. 30, 2023, and they relied solely on section G data. Since April 2024, the outcomes for these four measures have been held constant (i.e., frozen):

• Percent of Residents Who Made Improvements in Function (short stay)

• Percent of Residents Whose Need for Help With Activities of Daily Living Has Increased (long stay)

• Percent of Residents Whose Ability to Move Independently Worsened (long stay)

• Percent of High-Risk Residents With Pressure Ulcers (long stay)

A Glimpse of Light

Shortly after the freeze, NACs began seeing data for the new measures reported in the Internet Quality Improvement and Evaluation System (iQIES). The iQIES reports applied the new measures and updated specifications using section GG for assessments with assessment reference dates (ARDs) of Oct. 1, 2023, and later. This table summarizes the key changes to the measures:

Frozen Measure
(
April 2024)
New Measure
(Effective October 2023)
Key Changes
Percent of Residents Who Made Improvements in FunctionDischarge Function Score
  • Replaced by the Skilled Nursing Facility Quality Reporting Program (SNF QRP) measure

  • Delayed public reporting to January 2025 (per CMS memo QSO-25-01-NH)
Percent of Residents Whose Need for Help With Activities of Daily Living Has IncreasedPercent of Residents Whose Need for Help With Activities of Daily Living Has Increased
  • Replaced section G late-loss ADLs (i.e., bed mobility, eating, transfer, and toileting) with GG items:

    • Sit to Lying (GG0170B)

    • Sit to Stand (GG0170D)

    • Eating (GG0130A)

    • Toilet Transfer (GG0170F)
Percent of Residents Whose Ability to Move Independently WorsenedPercent of Residents Whose Ability to Walk Independently Worsened
  • Slight name change

  • Includes only residents who can walk 10 feet

  • Excludes residents using wheelchairs

  • Uses GG data
Percent of High-Risk Residents With Pressure UlcersPercent of Residents With Pressure Ulcers
  • Slight name change

  • Removed high-risk stratification

  • Includes all long-stay residents with pressure ulcers

  • Uses GG data

Murky Early Data

Unfortunately, many of the iQIES reports for the new measures were incomplete or inaccurate due to the updated specifications. For example, two measures—Need for Help With ADLs Increased and Ability to Walk Independently Worsened—require comparison between a target and prior assessment. Because only assessments with ARDs on or after Oct. 1, 2023, are included, many residents needed up to six months to meet the criteria for the denominator. This situation led to anomalies in early data, with some facilities showing disproportionately high percentages that will now impact the Five-Star ratings in January.

The Big Thaw

CMS announced the freeze will end with the January 2025 Care Compare refresh and the updated measures will be reported publicly. However, the time frame of this data will cover the period from Oct. 1, 2023, to Sept. 30, 2024, for Minimum Data Set (MDS) 3.0 measures. (Note: The 12-month data collection period may differ for the Discharge Function Score measure because it is a SNF QRP measure). So, although NACs may have monitored these measures in iQIES over the last several months, when the public gets their first look at the numbers, it will contain an entire year’s worth of data.

Clear Communication with Leadership and the Public

NACs must be aware of how the facility performed on the new measures and review the results with leadership. These measures directly affect the Five-Star rating, so facilities may see changes in their QMs and overall stars. Facility leaders need to be prepared to discuss these changes with consumers and stakeholders, ensuring transparency and readiness for public reporting.

Conclusion

The unfreezing in January does not just update the measures using section GG. Importantly, it is also a transition to the public reporting of these new measures. The similarity in names can be confusing, and stakeholders and consumers may tend to compare the new measures with the old ones. Thus NACs and facility staff must be prepared to explain why the measures can’t be compared, clarify how the transition has impacted their star ratings, and reassure the public that the facility continues to make efforts to improve resident care. The freeze certainly presented some challenges, but the thaw offers an opportunity to refocus on quality improvement efforts.

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