Home Health & Hospice Week

Commenters push back on OASIS burden.

If the mountain of new SPADE elements proposed for 2021 implementation isn’t enough to make your OASIS staff run screaming for the hills, three new OASIS items related to new health information transfer quality measures may do the trick.

In its 2020 proposed rule, the Centers for Medicare & Medicaid Services proposes adding these two new quality measures in 2022 supported by three new OASIS items in 2021 (see box, p. 305, for item details):

1. Transfer of Health Information to Provid­er–Post-Acute Care (supported by data from new OASIS items A2121A, A2121B, and A2123); and
2. Transfer of Health Information to Patient–Post-Acute Care (supported by new OASIS items A2121 and A2123).

“Both of these proposed measures support our Meaningful Measures priority of promoting effective communication and coordination of care, specifically the Meaningful Measure area of the transfer of health information and interoperability,” CMS notes in the proposed rule published in July.

A pilot test of the items and measures that included seven home health agencies already took place in 2018, CMS says in the proposed rule.

Commenters were split on these new measures and supporting OASIS items. Some were positive. “Recognizing the importance of the communication between different care settings and with families is vital, particularly related to medications,” the Visiting Nurse Associations of America says in its comment letter on the proposed rule. “We are supportive of the proposal for the two new measures,” the trade group says.

Physical therapist Kade Erickson in Utah joined multiple other PTs and therapy clinicians in approving of the change. “I support CMS’ proposal to adopt the Transfer of Health Information quality measures beginning with the 2022 QRP,” Erickson said in his comment letter.

But other commenters oppose the new measures, mostly based on the sheer addition to OASIS burden represented by the transfer items and the 20 new standardized patient assessment data element (SPADE) items (see Eli’s HCW, Vol. XXVIII, No. 37).

The Illinois Home Care & Hospice Council “is seriously concerned that many home health providers will not survive the next year, as the impact of implementing a new payment model, significant reductions in the RAP percentage, continued phase-out of the rural add-on and required participation in the Review Choice Demonstration will overwhelm them to the point of closure,” IHHC President Cheryl Adams says in the state trade group’s comment letter. “Other CMS proposals planned for implementation in the years ahead, such as making significant revisions to the OASIS and requiring OASIS data to be collected and reported on all patients, indicates that CMS does not have a firm grasp on the consequences of these regulatory proposals on home health providers and the patients they serve.”

“We ask that CMS aggressively evaluate the OASIS data set and implement a limitation for the maximum number of assessment items that can be included at any given time,” said David J. Totaro with BAYADA Home Health Care headquartered in Philadelphia, in the chain’s comment letter on the 2020 proposed rule.

Some commenters took issue with the measures’ specifics. “There is high variability among HHAs industry wide in having electronic records or systems that are able to transmit this kind of information readily,” Lauren Simpson, president of Potomac Home Health Care based in Rockville, Maryland, says in a comment letter. “It is even more questionable if the information would be received properly from another provider in a different setting as systems and vendors are highly variable across care settings and there has not been an adequate push by HIT vendors for interoperability.”

Plus: “It would be very difficult for a home health clinician in the field to correctly identify the route of current reconciled medication list transmission and meet the measure (OASIS-E A2123),” Simpson adds.

Multiple commenters asked CMS to hold off on implementing new quality measures before they have gotten the stamp of approval from the National Quality Forum. “Delay the addition of any measures that are not endorsed by the NQF for the specific setting,” urges the Michigan Health & Hospice Association in its letter.

CMS takes a preemptive strike at this criticism in the proposed rule. “When a feasible and practical measure has not been NQF endorsed for a specified area,” the IMPACT Act allows the Department of Health & Human Services “to specify a measure that is not NQF endorsed as long as due consideration is given to the measures that have been endorsed or adopted by the consensus-based entity under a contract with the [HHS] Secretary.” CMS maintains “there is currently no feasible NQF-endorsed measure that we could adopt” and says it “intend[s] to submit the proposed measure[s] to the NQF for consideration of endorsement when feasible.”

Brace yourself: With so many OASIS additions proposed, “OASIS changes are going to happen,” warns Morton Grove, Illinois-based software vendor Pragma-IT in its blog. “CMS wants to be able to view and compare data across the post-acute care continuum and this requires we all ‘speak the same language.’ Changes to the OASIS directly reflect updates to other post-acute standardized assessments.”

Under PDGM, “it is vital that your clinicians can be independent in understanding and completing OASIS documents and verifying referral information such as institutional stays and diagnosis codes,” Pragma-IT adds.

Note: The proposed rule is at www.govinfo.gov/content/pkg/FR-2019-07-18/pdf/2019-14913.pdf. Medicare’s OASIS contractors Abt Associates and RAND Corp. include the proposed OASIS items and their details in a 149-page report at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Post-Acute-Care-Quality-Initiatives/Downloads/Proposed-Specifications-for-HH-QRP-Quality-Measures-and-SPADE.pdf.