Home Health & Hospice Week

The OIG notes in a new report that HHAs failed to report at least 55 percent of required falls with major injuries (see related story, p. 254). The watchdog agency makes four recommendations to the Centers for Medicare & Medicaid Services to rectify the problems it uncovered:

1. CMS should take steps to ensure the completeness and accuracy of the HHA-reported OASIS data used to calculate the falls with major injury quality measure. Those steps could range from providing more education and training for HHAs to comparing OASIS data with inpatient claims data, as the OIG did, in order to identify missed falls.

Watch out: And “CMS could encourage state agencies to focus on the accuracy of falls reporting, and other questions used to generate quality measures, when auditing OASIS assessments as part of the survey process,” the OIG urges. “CMS could then use this information to target OASIS falls data improvement efforts,” it adds.

2. Medicare should use more non-OASIS data sources to improve the accuracy of the falls QM. The agency “could consider using a combination of Medicare claims … and provider-reported OASIS data to generate a more accurate measure of the rate of falls with major injury among people using home health,” the OIG advises. “Given the low reporting rates found in this study, this could help CMS to estimate fall rates more accurately than the provider-reported assessment data alone.”

3. CMS should ensure HHAs submit required OASIS assessments when their patients are hospitalized. In addition to more training and education, CMS may want to implement “automated checks to identify inpatient hospital claims … and alert HHAs if the required OASIS assessments are not submitted in a timely manner,” the OIG offers. The agency could also require state surveyors “to check for completion of assessments when home health patients are hospitalized as part of the survey process,” the report says.

And “CMS should target efforts aimed at improving compliance with OASIS submission requirements … to HHA’s managed care patients,” although the OIG doesn’t lay out any specifics on how to do so.

4. Medicare should explore whether it can use improvements to the falls QM to also improve the accuracy of other home health measures. “CMS should consider opportunities to improve additional home health quality measures that are based solely on OASIS assessment data,” the OIG exhorts. Whatever proves useful, from survey focus to education, should work across all the OASIS-based QMs (see those in box, p. 255).

In a response letter to the report, CMS Administrator Chiquita Brooks-LaSure concurs with all four recommen­dations and references the agency’s CMS National Quality Strategy launched in 2022. The “ambitious long-term initiative … aims to promote the highest quality outcomes and safest care for all individuals” and “incorporates lessons learned from the COVID-19 Public Health Emergency,” Brooks-LaSure tells the OIG.

“CMS is dedicated to empowering consumers, their families, and their caregivers by giving them the resources they need to make informed decisions regarding their care,” Brooks- LaSure stresses in the letter. CMS “understands the importance of providing accurate quality information to home health agencies and the public” and “is consistently looking for ways to improve the quality of care, including the completeness and accuracy of the information used to assess quality,” she adds.

CMS’ somewhat uncharacteristic wholesale agreement with the OIG’s recommendations means HHAs are likely to see related changes teed up sooner rather than later.

“Agencies need to wake up and get serious about this reporting,” urges Pam Warmack with Clinic Connections in Ruston, La. “It takes a lot of staff education on an ongoing basis,” she stresses.

Following this report, HHAs are likely to see “a greater emphasis on confirming OASIS accuracy as part of the survey process,” predicts Cindy Krafft with Kornetti & Krafft Health Care Solutions in Florida. Providers should also expect “further movement towards data outside of OASIS to determine quality,” Krafft adds.

Tip: HHAs may want to take a page from Warmack’s clients’ book. They have “made Falls resulting in ER and hospitalization a Performance Improvement Project [under QAPI] and have learned a lot about their patients and themselves,” she relates.

Reminder: As of 2018, “having a Quality Assurance and Performance Improvement (QAPI) program is mandated by the … Home Health Conditions of Participation (CoPs),” software vendor HEALTHCAREfirst notes on its website.

And don’t be surprised to see an “increase in similar analysis of other outcomes,” Krafft tells AAPC.