Home Health & Hospice Week

Expect new process-based quality measures in coming years.

In addition to being a regulatory requirement, you soon must submit OASIS data to secure your full reimbursement update from Medicare.

New penalty: In its final rule implementing home health prospective payment system rates for 2007, the Centers for Medicare & Medicaid Services spells out that home health agencies will see a 2 percent reduction to their PPS payment rates if they fail to submit OASIS data. That would translate to a base payment rate of $2,293.72.

Home health pay for reporting "is something we look forward to implementing," CMS' Herb Kuhn said in a Nov. 1 press conference.

The usual exceptions to OASIS data submission still apply for purposes of payment, notes consultant Regina McNamara with Kelsco Consulting Group in Cheshire, CT. Those include private pay and maternity patients and agencies that are newly certified.

Only about 1 percent of certified agencies fail to report OASIS data, says consultant Judy Adams with LarsonAllen based in Charlotte, NC.

"Any agency that is not submitting its OASIS data probably has many other problems and will not survive anyway," predicts Abilene, TX-based consultant Bobby Dusek.

Setting the Stage for Pay For Performance

Congress required the OASIS reporting requirement as an initial step in its plan to reach a pay-for-performance payment system. The OASIS data reporting supports the 10 home health quality initiative measures listed on Medicare's Home Health Compare Web site, CMS notes.

CMS plans to pursue new process-based quality measures for HHAs as well, the agency announces in the rule. "These process measures would refer to specific care practices that are, or are not, followed by the home health agency for each patient," CMS says.

Example: The percentage of patients at risk of falls for whom fall prevention was addressed in the care plan, CMS offers.

CMS plans to introduce the new measures in 2008 and 2009 and make them part of the OASIS tool, it says. "Any future quality measures should be evidence-based, clearly linked to improved outcomes, and able to be reliably captured with the least burden to the provider," the agency adds.

"I think agencies will be fine with process measures if we can figure out how they will be measured," Adams forecasts.

But McNamara remains skeptical that the burden on agencies will be minimized.

And McNamara protests a P4P system based on outcomes that might not be under an agency's control. "It ignores all the many other variables that affect patient outcomes," she tells Eli.

Despite the industry's concerns, P4P is coming and agencies had better start to prepare for it, experts warn.

Act now: That means improving outcomes and generally streamlining operations to be as efficient as possible, Adams advises. Agencies may get more clues to how home health P4P will look when CMS releases information on how the upcoming P4P demonstration project may be structured. v

Note: To receive a copy of the final rule, email editor Rebecca Johnson at rebeccaj@eliresearch.com with "2007 Payment Rates" in the subject line.