Home Health & Hospice Week

Can agencies really achieve 90 percent?

The proposed July 2015 deadline for hitting a new OASIS submission benchmark is coming up fast, and it could take a 2 percent bite out of your payments.

Reminder: For the first time, the Centers for Medicare & Medicaid Services will require a “minimum submission threshold” for OASIS, the agency proposes in the rule published in the July 7 Federal Register. CMS plans “to require all HHAs to achieve a Pay-for-Reporting performance requirement compliance rate of 90 percent or more,” the agency says in the 2015 home health prospective payment system proposed rule issued July 1. In other words, HHAs must submit both admission and discharge OASIS assessments for a minimum of 90 percent of all patients with episodes of care occurring during the reporting period, CMS explains in a fact sheet about the rule.

“Only those OASIS assessments that contribute, or could contribute, to creating a quality episode of care are included in the computation” for the benchmark, CMS notes in the rule.

However, CMS will give agencies some time to come into compliance with the new requirement. The agency proposes that agencies must submit 70 percent of “Quality-Assessment-Only” assessments in 2015, 80 percent of QAO assessments in 2016, and then reach 90 percent in 2017.

The consequence: HHAs that do not meet the QAO metric benchmark will face a 2 percent reduction, CMS says. The first year’s data will affect payment rates for 2017.

Commenters on the PPS rule gave CMS a piece of their mind about the proposed requirement.

The commenters who addressed this issue were generally supportive of establishing an OASIS submission benchmark. “It would appear that some agencies have been given a pass,” exclaims a commenter from Athens Regional Home Health in Georgia. “Since it is a regulatory requirement to submit all OASIS data, how have agencies been allowed to continue to operate without compliance?” asks Athens’ Executive Director Pamela Hall in the letter.

“HAP supports CMS’ proposed OASIS data completeness standards,” says the Hospital & Healthsystem Association of Pennsylvania in its comment letter on the rule. “Home health quality data are publicly reported and used by home health agencies and patients to gauge improvement. A data completeness standard would help to ensure home health quality measure data are accurate.”

But while the idea may have support, some of CMS’s implementation details don’t, the comment letters show. CMS proposes a July 2015 start date for the requirement.

On one hand: The National Association for Home Care & Hospice says it “appreciates CMS’ willingness to phase-in the required performance percentage over three years,” according to its comment letter. NAHC believes agencies will be able to meet that first-year goal of 70 percent.

On the other hand: Such a short timeline is not a good idea, says Hall. “Agencies should first be allowed the opportunity to work with/understand the data and have access to their current rate so there is opportunity to improve if below the 70 percent threshold,” Hall tells CMS. “Without the final rules and knowing the processes involved in transmitting, aggregating, tabulating and interpreting the data, the interim between the final rule and July 1, 2015 is a very short time frame to implement and achieve compliance.”

Suggestion: Hall pitches July 2016 as a more appropriate start date for the requirement. That delay, “using the interim period for agencies to receive baseline rates and work on improvement, if needed, seems more reasonable,” she says.

Whatever date CMS settles on, NAHC urges the agency to commence training on the requirement at least six months ahead of time, the trade group says in its letter.

And while NAHC believes agencies can hit the 70 percent benchmark the first year, it is not as sanguine about achieving the final 90 percent mark CMS aims for in the proposed rule.

“Without further analysis, it is unknown whether a 90 percent, or even an 80 percent, compliance rate is a realistic goal,” NAHC contends. “CMS should carefully monitor compliance rates over the next two years to determine if a 90 percent compliance rate” is realistically doable.

Commenters urge CMS to make some other changes to the requirement as well. For example, “HAP … recommends that CMS provide home health agencies with a 30-day period in which to review CMS’ assessment of their compliance and submit corrections if necessary,” the trade group says. “CMS uses a similar process for its other health care provider quality reporting programs. Given that 2 percent of payments are tied to compliance with this standard, we believe it is in the best interest of patients needing home care for home health agencies to have the opportunity to ensure CMS’ findings are correct.”

Submission May Not Be Good Enough

And NAHC urges CMS to “clarify whether the standard requires both submission and acceptance and whether OASIS acceptance must be within the performance period,” it says in its letter. “CMS consistently uses the term ‘submission’, when in fact; we suspect CMS intends that the OASIS must be accepted into the state database during the performance period to count toward the submission threshold.”

NAHC also recommends that CMS “clarify that a patient who has only recertification assessments recorded during a performance period will not be included in the quality assessment rate calculation,” it says. “This will accommodate long term patients where a SOC/ ROC assessment would have been conducted prior to the performance period.

Final rule: Home health agencies soon will see whether CMS has listened to commenters’ feedback. CMS is expected to issue the final rule by early November. 

Note: To peruse the 354 comments on the proposed rule, go to www.regulations.gov, search for “CMS-2014-0090,” click on the rule entry, scroll down to the “Comments” section, and click on “View All.” Or email editor Rebecca Johnson at rebeccaj@eliresearch.com for a free link to the comment section — include “2015 PPS rule comments” in the subject line.