Home Health & Hospice Week

You have only days left to comment on the feds' proposed post-acute assessment tool--but stay tuned even if you miss your initial chance to weigh in.

Background: The Centers for Medicare & Medicaid Services is set to launch its $6 million Post Acute Care Payment Reform Demonstration (PACPRD) in January. Created by the Deficit Reduction Act of 2005, the demonstration aims to examine the costs and outcomes for similar diagnoses across different post-acute care settings.

Specifically, the plan will examine differences in costs and outcomes for post-acute care (PAC) patients of similar case mix who use four different types of PAC providers, says Barbara Gage of RTI International, the contractor CMS is using for the project.

With that goal in mind, CMS and RTI have created a draft version of a new standardized patient assessment tool, the Continuity Assessment Record and Evaluation (CARE) tool (see Eli's HCW, Vol. XVI, No. 27). The CARE tool, which has already been pilot tested, is to be used by acute hospitals at discharge and by post-acute providers at admission and discharge.

Deadline: Stakeholders have until Sept. 25 to submit comments on the draft assessment instrument.

Though the instrument is a daunting 26 pages on paper, the tool--and the demonstration--could herald positive changes for home health agencies, says Judy Adams, a clinical consultant with LarsonAllen in Charlotte, NC.

Eventually, the assessment tool could replace similar items on the existing Medicare assessment forms, including the OASIS.

"The idea of having one assessment tool is a positive concept," says Adams. "We can begin to compare clients' needs and characteristics--and how their outcomes vary depending on the setting in which they receive care." And the benefits for agencies could be longterm, says Adams, given that some recent studies support home health as a cost-effective post-acute provider.

Get technical: The tool nudges providers to make better use of technology. In the long run, that could be a positive for HHA striving for efficiencies. But investing in technology could be difficult for many providers these days, especially given Medicare cuts on the horizon.

The transition to a more unified approach to post-acute assessment, and potentially payment, won't be easy for home health agencies, caution experts.

"The timing is really complex," notes Adams. HHAs are already doing more with less--all in the face of at least three other major changes under Medicare--post-acute payment reform, OASIS refinements and the much-talked-about but slow-to-progress pay-for-performance demonstration.

For small agencies in particular, the PAC-PRD could wind up to be "just one more thing" in a sea of change, says Adams.

Be heard: Small agencies that feel ill prepared to step up as demonstration volunteers may want to think twice. If CMS enrolls primarily large home health agencies in the demonstration, the final CARE tool could wind up to be a poor match for smaller HHAs, making it harder for small agencies to thrive when CMS adopts post-acute assessment and payment.

"It's easy to look the other way at this point, but the truth is, yes, this demonstration may well affect you," asserts Adams.

CMS has pledged to choose participants "to represent variations in geographic location, population density, PAC provider availability, patterns of corporate ownership and other factors."