Home Health & Hospice Week

Make sure M2001-M2005 don’t trip up your quality scores — or compliance.

You need to be positive your clinicians are all on the same page when it comes to medication issues, or the authorities may throw the book at you.

Multiple commenters on Medicare’s 2017 Home Health Prospective Payment System final rule noted the problems with the vague new quality measure, Drug Regimen Review Conducted with Follow-Up for Identified Issues for the HH QRP.

Particularly troublesome was the gray area surrounding the “potential clinically significant medication issues” the measure requires home health agencies to identify and communicate to the physician to address. CMS needed to clarify that definition, many agencies said. “In the absence of such clarity an HHA is without guidance in understanding the measure, as well as opportunities for improvement,” warned Interim HealthCare in its comment letter on the proposed rule.

“To ensure accurate measure comparison and data exchange among the post-acute care providers, we urge the developers to establish a clear definition for the terms ‘clinically significant’ medication issues,” the National Association for Home Care & Hospice said in its comment letter.

CMS response: “For this measure, potential clinically significant medication issues are defined as those issues that, in the clinician’s professional judgment, warrant interventions, such as alerting the physician and/or others, and the timely completion of any recommended actions (by midnight of the next calendar day) so as to avoid and mitigate any untoward or adverse outcomes,” the Centers for Medicare & Medicaid Services said in the final rule published in the Nov. 3 Federal Register.

CMS’s definition should help agencies “a lot,” says OASIS expert Lisa Selman-Holman with Selman-Holman & Associates and CoDR — Coding Done Right in Denton, Texas. Very significantly, this definition shows agencies how to legitimately lighten their burden under this measure. “There are issues that can be resolved by the agency without physician intervention as part of the drug regimen review,” Selman-Holman explains. “There are issues that need some physician communication, but it’s not necessary to hear back within the time frame; and then there are issues that we need intervention from the physician right away. Those we need to be diligent and get some direction from the physician.”

The OASIS-C2 Manual elaborates with some examples of potential clinically significant medication issues. “Potential or actual clinically significant medication issues may include but are not limited to adverse reactions to medications (such as a rash), ineffective drug therapy (analgesic that does not reduce pain), side effects (potential bleeding from an anticoagulant), drug interactions (serious drug-drug, drug-food and drug-disease interactions), duplicate therapy (generic name and brand name equivalent drugs are both prescribed), omissions (missing drugs from an ordered regimen), dosage errors (either too high or too low), [and] nonadherence (regardless of whether the nonadherence is purposeful or accidental),” says the manual’s itemby- item guidance.

But it’s up to agencies to nail down the specifics. HHAs must create “a policy/process, both internally and within their associated software, by which they define what is a potential clinically significant medication issue related to appropriate medication dosages, usage, side effects, contraindications and potential adverse reactions, as well as high-risk or high-alert and hazardous medications and look-alike/sound-alike medications,” advises consultant Anna Doyle. “Using this process upon admission and subsequent follow-up visit medication reconciliation would immediately identify any potential clinically significant issues to report to the physician.”

Bonus: In the manual, CMS also elaborates that “if the physician/physician-designee recommends an action that will take longer than the allowed time to complete, then Response 1 — Yes should be entered as long as by midnight of the next calendar day the agency has taken whatever actions are possible to comply with the recommended action.” Examples might include “physician instruction to agency staff to continue to monitor the issue over the weekend and call if problem persists, or the physician instructs the patient to address the concern with his PCP on a visit that is scheduled in two days,” CMS offers.

HHAs can also mark “Yes” when the physician’s feedback is to do nothing. “If … the physician/physician-designee provided no new orders or instruction in response to the timely reported concern, Response 1 — Yes should be reported, indicating that the physician/physician-designee was contacted and prescribed/recommended actions were completed.”

CMS’s language “allows us to answer yes on M2003 when we’ve done what we can within the physician’s instructions within the midnight time frame [and] adds more flexibility,” Selman-Holman cheers.

Note: The OASIS-C2 Manual is at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/OASIS-C2-Guidance-Manual-6-17-16.pdf.