Home Health & Hospice Week

CMS finalizes elimination of 34 measures.

It’s always a pleasant surprise when Medicare reduces your workload, but the elimination of 34 quality measures could have an unintended consequence.

In its 2017 Home Health Prospective Payment System final rule, the Centers for Medicare & Medicaid Services adopts its proposal to eliminate 28 Home Health Quality Improvement measures because they are either “topped out” or otherwise clinically insignificant (see list of eliminated measures, p. 315).

CMS settled on the measures for elimination in an effort to streamline the program, the agency notes. The cut leaves 53 HHQI measures intact. The change will take effect Jan. 1. CMS also follows through on its proposal to cut six process measures from the Home Health Quality Reporting Program for being topped out as well (see box below), according to the rule published in the Nov. 3 Federal Register. The elimination will take effect with the 2018 payment determination, CMS notes in a fact sheet about the rule.

However: “The data for the measures no longer included in the HHQI or removed from the HH QRP may still appear on OASIS for previously established purposes that are not related to our HH QRP, and if still collected will be available to home health agencies, via the CASPER on-demand reports, for the purpose of monitoring and improving quality efforts,” CMS says in the rule.

Many of the 89 commenters on the proposed rule supported elimination of the measures. But the move doesn’t go far enough, said the Association for Home Care & Hospice of North Carolina and South Carolina in its comment letter on the proposed rule. “These measures should also be removed from the CASPER reporting system,” the trade group told CMS. “There are far too many quality measures calculated from the OASIS for an agency to be able to address. We would like to see a dashboard of key quality measures available rather than a long menu that agencies can choose from. We support a single dashboard of quality measures and the alignment of measures across ... CASPER reporting, public reporting on the Home Health Compare website, the star rating calculations, and value-based purchasing.” But CMS shrugged off those concerns in the final rule without directly responding to them.

CMS also doesn’t have much to say to commenters’ frequent pleas to prioritize stabilization measures in HHQRP. “We believe that maintenance of function and avoidance or reduction in functional decline are appropriate goals for some home health patients,” CMS allows in the final rule. “As we continue to develop and refine standardized function measures, we will continue to assess and account for the unique characteristics of home health patients and the home health setting,” the agency says.

Prioritize Best Practices

In the rule, CMS acknowledges widespread support for removing topped out measures. But the move isn’t without risk. “While we are supportive of their removal, we do have some concerns regarding perfunctory removal of topped out measures from payment determinations,” cautioned UnityPoint at Home based in Urbandale, Iowa.

“First, we are concerned regarding public perception,” the health system-based agency said in its comment letter. “If several or all topped out measures are removed, there is a risk that public perception will erode as HHAs’ scores may experience fluctuation when several topped out scores are replaced in favor of new metrics.”

Best practice: “Second, many of the topped out measures are best practices from national quality boards related to monitoring, assessing and treating certain condition[s],” UnityPoint said. “We are concerned the removal of all topped out measures will divert HHAs from implementing best practices as recommended. For example, the National Pressure Ulcer Advisory Council recommends pressure ulcer risk assessment (i.e. Braden) interventions to be incorporated in the plan of care and implemented.”

Instead: CMS should “monitor removed topped out measures to assure that quality does not decrease,” UnityPoint said. But the agency didn’t respond to that specific comment in the final rule.

Note: The final rule is at https://federalregister.gov/d/2016-26290.