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The 2018 Home Health Proposed Rule was released 07/28/17. The 2018 Home Health Proposed Payment Rule – Including Intro to HHGM regarding this rule primarily discussed the proposed reimbursement changes for 2018 as well as the massive changes to the Prospective Payment System in the form of HHGM. The following is a recap of the proposed changes to the Home Health Quality Reporting Program (HH QRP).

CMS is seeking public comment on which social risk factors might be most appropriate for reporting stratified measure scores and potential risk adjustment of a particular measure. Examples: dual eligible/low-income subsidy, race and ethnicity and geographic area of residence.

CMS is also proposing to remove 247 data elements from 35 OASIS items collected at specific time points. These elements are not used in the calculation of quality measures nor are they used for payment, survey, VBP or care planning.

The IMPACT Act requires that there be standardized patient assessment data and corresponding quality measures across the Post Acute Care (PAC) providers of Medicare services. To achieve a level of standardization, across HHAs, LTCHs, IRFs, and SNFs that enable CMS to make comparisons between them. CMS is proposing to define “standardized patient assessment data” as patient or resident assessment questions and response options that are identical in all four PAC assessment instruments, and to which identical standards and definitions apply.

The goal is determining which data to include is to identify standardized patient assessment data that could be feasibly incorporated into the LTCH, IRF, SNF, and HHA assessment instruments and that have the following attributes:

  1. Being supported by current science;
  2. Testing well in terms of their reliability and validity, consistent with findings from the Post-Acute Care Payment Reform Demonstration (PAC PRD); (3) the potential to be shared (for example, through interoperable means) among PAC and other provider types to facilitate efficient care coordination and
  3. The potential to be shared (for example, through interoperable means) among PAC and other provider types to facilitate efficient care coordination and improved beneficiary outcomes;(4) the potential to inform the development of quality, resource use and other measures, as well as future payment methodologies that could more directly take into account individual beneficiary health characteristics; and (5) the ability to be used by practitioners to inform their clinical decision and care planning activities.
  4. The potential to inform the development of quality, resource use and other measures, as well as future payment methodologies that could more directly take into account individual beneficiary health characteristics;
  5. The ability to be used by practitioners to inform their clinical decision and care planning activities.

Following are the Standardized Assessment Domains that specific standards would have to be finalized for:

  • Functional status
    • Application of Percent of Long‐Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631)
  • Cognitive function and mental status
    • Brief Interview for Mental Status (BIMS)
    • Confusion Assessment Method (CAM)
    • Behavioral Signs and Symptoms
    • Patient Health Questionnaire‐2
  • Special services, treatments, and interventions
    • 16 items – including cancer, respiratory treatments, intravenous therapy, tube feedings, etc.
  • Medical conditions and co‐morbidities
    • Elements needed to calculate the current measure for pressure ulcers will be used such as diabetes, incontinence, peripheral vascular disease or peripheral arterial disease, mobility, as well as low body mass index (BMI)
  • Impairments
    • Hearing & Vision

The proposed Standardized Assessment Data would be added to the OASIS dataset so no need to develop a new tool for collection.

Following are the Quality Measure Domains that specific standards would have to be finalized for:

  • Skin integrity and changes in skin integrity;
  • Functional status, cognitive function, and changes in function and cognitive function;
  • Medication reconciliation;
  • Incidence of major falls;
  • Transfer of health information and care preferences when an individual transitions;

Resource Use and Other Measure Domains:

  • Total estimated Medicare spending per beneficiary (MSPB);
  • Total estimated Medicare spending per beneficiary (MSPB);
  • Discharge to community;
  • All‐condition risk‐adjusted potentially preventable hospital readmissions rates.

PROPOSED NEW MEASURES for 2019 assessment – calculated measures 2020

CMS is proposing to replace the current pressure ulcer measure entitled Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short Stay) (NQF #0678) with a modified version of the measure and to adopt one measure on patient falls and one measure on assessment of patient functional status.

The proposed measures are as follows:

  • Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury.
  • Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF #0674).
  • Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631).

CMS is currently considering four measures that would assess a change in functional outcomes such as self-care and mobility across a HH episode. These measures (see Table 48) would be standardized to measures finalized in other PAC quality reporting programs, such as the IRF QRP. Agencies are invited to provide feedback on the importance, relevance, appropriateness, and applicability of these measure constructs.

Table 48 - HH QRP Quality Measures Under Consideration for Future Years

CMS is seeking input on whether they should require quality data reporting on all HH patients, regardless of payer, where feasible—noting that because Medicare Part A claims data are submitted only with respect to Medicare beneficiaries, claims based measures rates would continue to be calculated only for Medicare beneficiaries.

This Proposed Rule carries massive implications for home care. Both from a reimbursement standpoint and a documentation standpoint. Please join us for the HPS Alliance Members webinar on August 17 when we will review the rule and join us in person for the State of Home Health PPS Workshop on August 22 that will cover this rule and much more.