Home Health & Hospice Week

Section GG to expand.

Get ready to put some serious resources into OASIS education and training in 2018, thanks to new requirements spelled out in the 2018 HH PPS Final Rule.

On One Hand: Burden Lifted

The Centers for Medicare & Medicaid Services did make some strides in reducing Home Health Quality Reporting Program burden, the agency maintains. It will trim 33 OASIS items from data collection starting in January 2019 (see specific items, p. 224), the agency notes in a fact sheet about the final rule. CMS removed the items "because they are no longer required for the calculation of quality measures, prospective payment, provider survey, the HH Value Based Purchasing (VBP) Model or care planning. The removal of these items will reduce time and paper required to complete HH patient assessments," the agency boasted.

CMS also whittled HH QRP burden by "finalizing exception and extension requirements, and reconsideration and appeals procedures," according to the fact sheet. Overall, "the estimated net burden reduction associated with the changes to the HH QRP in this year's rule, which includes the removal of these OASIS items, was over $145 million. This corresponds to an estimated net reduction in HH clinician burden of over 2 million hours annually."

CMS estimates "the total average decrease in cost associated with changes to the HH QRP at $12,016.33 per HHA annually," it says in the final rule. "This corresponds to an estimated reduction in clinician burden associated with changes to the HH QRP of 166 hours per HHA annually.

CMS also reined in the proposed HH QRP burden by holding off on finalizing new OASIS items and resulting data collection for IMPACTActrequired areas such as cognitive function, swallowing and nutrition status, and treatment and services.

The proposed items would have been in new sections on hearing, speech and vision (Section B), cognitive patterns (Section C), behavioral symptoms (Section D), active diagnoses (Section I), swallowing/nutritional status (Section K), and special treatments, procedures and programs (Section O).

On The Other Hand: Burden Imposed

But that leaves home health agencies with plenty of new HH QRP responsibilities on their hands, according to the rule published in the Nov. 7 Federal Register.

Now: Currently, there's only one item HHAs collection in Section GG: Functional Abilities and Goals - GG0170C Mobility.

Then: In 2019, CMS will add three GG Section items, CMS explains in a 2019 OASIS Change Table on its OASIS website:

• GG0100 Prior Functioning: Everyday Activities;
• GG0110 Prior Device Use; and
• GG0130 Self-Care.

CMS will also add two items in Section J: Health Conditions:

• J1800. Any Falls Since SOC/ROC, whichever is more recent; and
• J1900. Number of Falls since SOC/ROC, whichever is more recent.

All but one of the five GG and J items are brand new. GG0100 is converting over from the current M1900: Prior Function.

CMS seems to be seriously undervaluing the burden of these OASIS changes, the National Association for Home Care & Hospice warned in its comment letter on the 2018 HH PPS proposed rule.

While the 33 eliminated items will result in the collection of fewer data elements at specific time points, the newly added items "will likely cause more burden for home health agencies to collect than those that are proposed to be removed since they are new assessment items," the trade group said.

"CMS has significantly underestimated the cost associated with the proposed changes to the OASIS assessment and the HHQRP," NAHC continued. "Any time significant changes are made to the OASIS assessment ... the burden for agencies is great."

Why? "Burden includes time and costs required for staff training, data set changes, and the opportunity cost associated with the learning curve needed to achieve competence in completing new assessment items," NAHC explained.

Agencies' burden will likely be exacerbated by a short timeline for ramp-up, NAHC fears.

"NAHC anticipates that it will take much of 2018 for CMS to finalize the proposed changes and develop and issue a revised OASIS assessment instrument," the trade group said.

NAHC urged CMS to give agencies at least a year from OASIS finalization before implementing those changes, but CMS is sticking with its January 2019 deadline for the new items, according to the materials posted on its OASIS website.

And the burden doesn't stop with the OASIS tool itself. CMS also will be implementing two new HH QRP measures and swapping out a pressure ulcer measure, although those will debut in 2020. (See new measures, below.)

CMS is also considering adding more IMPACT Act-based measures in future years (see story, p. 224).

Multiple commenters on the rule told CMS to reconsider its burden estimates. But for its proposal to replace the current pressure ulcer measure with a modified version of that measure, CMS noted it would be adding "a total of two items to be added to the OASIS, which were considered feasible for collection in post-acute care settings. We believe these items add minimally to the quality reporting burden."

For perspective on CMS's attitude toward additional administrative burden for HH QRP, you can look to last year's HH PPS final rule. Specifically, one commenter said "that even measures that rely on existing claims data can pose additional administrative burden, such as time and effort to compile and validate data," the rule noted.

CMS dismissed that idea. "With all new measure development, we are committed to assessing the burden and utility of proposed measures," the agency said in the rule. But when measures are calculated "using assessment items already in OASIS instrument," they add "no new burden for HHAs."

Likewise, claims-based measures "are calculated using claim files that should have been already compiled and validated by HHAs for other purposes, including reimbursement. Therefore, we do not believe that the adoption of claims-based measures creates a new administrative burden for providers."

It could be worse: "I am relieved that the number of new assessment items were not finalized and the burden associated with the volume of the assessment items implemented at one time is lifted," NAHC's Mary Carr says.

However: "The OASIS assessment in 2019 will be significantly different than it is today," Carr tells Eli. "Therefore, the concerns with changes in OASIS remain. It is still burdensome and costly, even if less so than anticipated."

Note: The final rule is at www.gpo.gov/fdsys/pkg/FR-2017-11-07/pdf/2017-23935.pdf.