There have been several updates to the Hospice Quality Reporting Program (HQRP) recently, most notably that CMS has provided notifications to hospices that were determined to be non-compliant with HQRP requirements for calendar year (CY) 2016, which will affect their fiscal year (FY) 2018 Annual Payment Update (APU). The non-compliance notification letters are dated July 18, 2017 and were sent via the US postal service and are also available in CASPER. The CASPER letter also identifies why the provider is non-compliant. We recommend hospices check their CASPER folder to determine if they received a notice letter. The consequence for non-compliance is a 2% reduction in the hospice’s annual payment update calculation for FY2018 (begins October 1, 2017).
A hospice that believes it has received a letter in error has 30 days, which is until August 17, 2017, to submit a reconsideration request to CMS. Instructions for the reconsideration request are in the letter and on the CMS Hospice Quality Reporting Webpage under the Reconsideration Request tab.
In addition to the letters of non-compliance, CMS has released a correction to the explanatory text of the HIS warning edit -3077. This warning edit relates to sections N-Medications and J-Health Conditions, and specifically the pain portion of section J. This change actually highlights some frequently asked questions we receive from providers about these two sections. We often see them completed incorrectly, and we want to take this opportunity to share with all providers how they should be completed. In Section J, item J-0905 Pain Active Problem can be answered “yes” (box 1) even if the patient does not have pain at the time of the clinician’s visit. In order to be answered “yes” in this situation, the clinician should consider factors such as historical report of pain, reports of recent symptoms, current for pain (pharmacologic and/or non-pharmacologic, etc. Generally, if the patient is currently taking opioids for pain, J-0905 would be answered “yes”. When the HIS is submitted, the response to N-0500 Scheduled Opioid and N-0510 PRN Opioid are compared to J-0905. It is expected that if the patient is actively taking a scheduled or PRN opioid, the patient is likely to have pain as an active problem. However, opioids can be prescribed for symptoms other than pain. Therefore, CMS is clarifying through their recent change to the explanatory text of warning edit -3077, that it is possible for N-0500 and/or N-0510 to be answered “yes” the patient is currently taking an opioid, and for J-0905 to be answered “no” pain is not an active problem for the patient. In these cases, the hospice can ignore the HIS warning edit -3077. The edit is present to alert hospices to verify that the responses to these items are correct.
Some hospices are reporting that their electronic medical record software will not allow J-0905 to be “no” if N-0500 or N-0510 is answered “yes”. This was a pattern developed by the software vendors most likely based on the former guidance from CMS on warning edit -3077, and this recent clarification from CMS will, hopefully, allow the vendors to update their software.
One other area of Section J of the HIS that we receive a lot of questions on, is Item J-0910 Comprehensive Pain Assessment. Some hospices ask how a comprehensive pain assessment can be completed when the patient is non-verbal or if the patient does not have pain as an active problem. In the latter, the HIS Manual instructs the hospice to skip J-0910 and go directly to J-2030 Screening For Shortness of Breath. However, a hospice should complete a comprehensive pain assessment and respond to J-0910 even if the patient is non-verbal. Caregiver reports and non-verbal indicators of pain such as moaning, protective body movements, and facial expressions can be used for a comprehensive pain assessment. Furthermore, CMS considers a comprehensive pain assessment to have been completed if any one of the seven characteristics listed on the HIS in J-0910 were completed or attempted by the clinician.
Please see the HIS Manual, V2.00 available on the CMS HIS webpage for further information.