Home Health & Hospice Week

Medicare may provide a little room on new dataset implementation, at least.

Hospice providers hoping for big changes to Medicare's quality data reporting plans -- or even just more specifics -- may be disappointed with the new home health prospective payment system final rule.

In the rule published in the Nov. 8 Federal Register, the Centers for Medicare & Medicaid Services finalizes its proposal to continue collecting two measures for 2014 (see related box, p. 317). But in the proposed rule back in July, CMS also floated a number of ideas and questions about its expansion of hospice quality data reporting in future years and received numerous passionate comments from industry members.

Most commenters were essentially fine with the two measures CMS is currently requiring hospices to collect data for. But they had a lot of constructive criticism regarding CMS's future plans (see Eli's HCW, Vol. XXI, No. 37).

CMS's brief section on hospice quality data reporting in the final rule leaves many of commenters' concerns unaddressed for now. "Unfor-tunately, there just was not a lot of information" in the final rule, says Judi Lund Person with the Na-tional Hospice & Palliative Care Organization.

How Soon Will You Have A Hospice OASIS Tool?

CMS does seem responsive to at least one of commenters' chief complaints. Numerous hospices protested that implementing a standardized data collection tool in 2014 would be too soon. That could put implementation of the tool, which observers liken to home health agencies' OASIS assessment form, as early as next fall, points out Holly Swiger with Weatherbee Resources in Hyannis, Mass.

CMS uses the phrase "Starting with data collection in 2015" when talking about plans for future measures. That may mean it wouldn't implement the data collection tool until then.

Or maybe not. The rule's language on the data collection tool start date is very unclear, Person tells Eli. "They could roll it out in '14, but it seems much more likely" to be later, she allows.

Pushing back the start date for the tool would be very helpful for hospices. "Just as it has been for every other industry," such as long-term care providers with the MDS and HHAs with OASIS, "when the full data set gets added to our work load, it will be a challenging adjustment and definitely add to our work load," Swiger cautions.

P4P coming: But while hospices may get a little breathing room on a data collection tool, they definitely should expect it to come relatively soon. "CMS is certainly aiming to eventually get all providers onto a pay-for-performance system," Swiger says. "What they need for this is a data set for hospice."

CMS has concluded its pilot test of a data collection tool. Contractor RTI facilitated the pilot at nine hospice locations around the country.

"The main purposes of the pilot were to get a clear understanding of the process of implementation of the item set by the hospices and of the burden experienced by the hospices as they implemented the item set and collected data on patients," CMS explains in the final rule. "The quantitative and qualitative results of the pilot test will be used to inform the continued development of the item set."

Get Your Favorite Measures Endorsed

Another complaint frequently voiced by commenters was that the current and proposed quality measures address only process and physical symptom topics, overlooking emotional, psychosocial and spiritual issues that are core to the hospice care experience.

CMS expressed sympathy with this problem. "We recognize the shortage of endorsed measures that reflect the essence of high quality hospice care, and will continue to look for opportunities to work with measure developers to address this challenge," the agency says in the final rule.

In other words: Hospices and other stakeholders need to get the measures they would like to see included endorsed by the National Quality Forum, CMS implies.

However, CMS does not say whether it will include two such measures already approved by NQF and frequently suggested by commenters: #1641 (patient preferences) and #1647 (spiritual issues addressed).

CMS also fails to do more than acknowledge complaints about the length and/or complexity of the Family Evaluation of Hospice Care Survey (FEHC) which makes up NQF endorsed measure #208. The agency wants to implement that survey, or one like it, after implementing other data collection.

While CMS's lack of details in the final rule may be frustrating, it is encouraging to see the agency taking its time with the quality data collection process, Swiger praises. CMS seems to be proceeding cautiously to assure "that the measures do what they intend to do in the measurement of quality," she says. "This has not always been the case with other industries."

Coming soon: CMS makes multiple references to upcoming rulemaking to nail down details it left unaddressed in this rule. Hospices should pay close attention when those proposals come out, experts urge.

Hospices should "respond to this current and all future proposed and final rules with input on any problems in implementing measures, as well as any problems in how they may not adequately reflect quality," Swiger exhorts. "This is quite probably what our future payment system will be built upon," she stresses.