Home Health & Hospice Week

Plus: Beware looming DC Function problems.

Like much of the rest of the home health landscape, quality-related policies are also up for change in the 2024 home health proposed payment rule.

The Centers for Medicare & Medicaid Services proposes adding two new quality measures for the home health quality reporting program starting in 2025:

1. COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date (Patient/Resident COVID-19 Vaccine).
2. Functional Discharge Score (DC Function).

“The COVID-19 Vaccine measure continues CMS’s commitment to promoting the uptake of the COVID-19 vaccine and ensures alignment with current CDC guidance,” CMS says in its rule fact sheet.

“As of March 15, 2023, vaccination rates among people age 65 and older are generally high for the primary vaccination series (94.3 percent) but lower for the first booster (73.6 percent) among those who received a primary series) and even lower for the second booster (59.9 percent) among those who received a first booster),” CMS notes in the rule released on June 30. “This proposed measure has the potential to increase COVID-19 vaccination coverage of patients in HHAs” and “prevent the spread of the virus within the HHA patient population,” the agency maintains. “Although this population receives services within their own homes, they can transfer the virus to their caretakers and home healthcare workers, who could then potentially infect other home health patients,” the agency points out.

Some home health observers wondered if CMS would initiate a QM regarding COVID vaccination for staff when it pulled back its rule mandating it, but so far no news on that front.

GG Data Could Trip Up HHAs

The DC Function Score will be more than a minor change from currently used measures.

“The final DC Function measure for a given HHA is the proportion of that HHA’s episodes where a patient’s observed discharge score meets or exceeds their expected discharge score,” CMS explains in the 352-page rule. “Functional status is measured through Section GG of OASIS assessments, which are cross-setting items. Section GG evaluates a patient’s capacity to perform daily activities related to three self-care (GG0130) activities and eight mobility (GG0170) activities,” the reg says.

Despite the fact that Medicare is just now proposing the adoption of DC Function for 2025, it still wants to include it as a Value-Based Purchasing measure beginning then as well (see story, p. 190).

“As I see it, we will still get paid off the PDGM items, and the GG items will drive outcomes for VBP,” offers industry veteran J’non Griffin with consulting firm SimiTree.

Watch out for potential troubles with that measure at first, Griffin warns. “We do not have a lot of ‘correct’ documentation with the GG items, because there wasn’t any concentration (outcomes or revenue) that were attached to it,” Griffin tells AAPC.

This will be one of the many areas that will require HHAs to spend time and resources on staff training.

“The rule does not come without additional burden and costs to organizations,” highlights consultant Angela Huff with FORVIS in Springfield, Mo. “It takes time and education dollars to shift gears with any changes, which takes money which is potentially being reduced” by the 2.2 percent cut, Huff says.

CMS also proposes publicly reporting the COVID vaccination and DC Function measures starting in 2025, as well as these two measures:

• Transfer of Health (TOH) Information to the Provider — Post-Acute Care (PAC) Measure (TOH-Provider);
• Transfer of Health (TOH) Information to the Patient — Post-Acute Care (PAC).

Your OASIS Burden May Lighten

CMS doesn’t only propose adding to HHAs’ quality reporting burdens.

The agency wants to remove these measures in 2025: Application of Percent of Long-Term Care Hospital (LTCH) Patients with an Admission Discharge Functional Assessment and a Care Plan That Addresses Function (Application of Functional Assessment/Care Plan) measure from the HH QRP beginning with the CY 2025 HH QRP. The DC Function measure will replace them, according to the fact sheet.

CMS also proposes removing two items from OASIS-E effective January 2025: M0110 — Episode Timing and M2220 — Therapy Needs. “These items are no longer used in the calculation of quality measures already adopted in the HH QRP, nor are they being used currently for previously established purposes unrelated to the HH QRP, including payment, survey, the HH VBP Model or care planning,” the agency reasons.

CMS estimates that the HH QRP changes will cost $5.1 million, according to the reg.

Note: The rule fact sheet is at www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-home-health-prospective-payment-system-proposed-rule-cms-1780-p.