Home Health & Hospice Week

Plus: COVID vaccination rates are about to become more important to HHAs.

Most of the quality-related provisions Medicare has finalized in the 2024 home health final rule will add to home health agencies’ burdens, but not quite all of them.

The Centers for Medicare & Medicaid Services will add these two new measures to the Home Health Quality Reporting Program:

CMS is finalizing the following measures beginning in 2025:

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

Uh oh: “I have serious concerns about the changes to the functional measurements,” says Cindy Krafft with K&K Health Care Solutions. “The limited number of [OASIS] GG items it will use focus now on rolling and sitting up — and not bathing, dressing and grooming — may not work the same in home health as is has in other post-acute settings,” Krafft worries.

“Add to it that the expected outcome for each of these will come from a mathematical calculation including risk adjustment and no ability of the clinician to identify the ‘goal,’” Krafft tells AAPC.

CMS is “compelled to move to the cross-setting GGs by the Impact Act,” Krafft says. But “so much time has passed since that started, and since home health was last to the party and currently has not received any data about those measures … it seems there should be some ability to make adjustments to get the best possible information for all concerned,” she maintains. Other PAC providers — long-term acute care hospitals, skilled nursing facilities and inpatient rehabilitation facilities have all received such data, Krafft observes.

CMS will swap out the new DC Function measure for the current Application of Percent of Long-Term Care Hospital (LTCH) Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (Application of Functional Assessment/Care Plan) measure in 2025.

HHAs Will Be On The Hook For Patients’ COVID Vax Rates

The COVID patient vaccination 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.

Many providers criticized this measure in their proposed rule comment letters. “While we understand the importance of COVID-19 vaccinations in preventing the spread of COVID-19, we have seen that there is significant hesitancy within the community to get vaccinated,” notes the Texas Association for Home Care & Hospice in its letter. “Despite the agency’s overall efforts to educate and offer, as well as encourage patients to stay up to date on their vaccines, it is still declined by many patients,” TAHC says. “This is out of the agencies’ control and should not be considered when determining the agencies overall quality of patient care,” it told CMS.

“This measure … is subject to many external factors outside the control of the HHA,” agreed UnityPoint at Home in its comment letter.

“We especially experience this hesitancy with our more rural patients,” reported Valerie Rivera with Wichita Home Health Service Inc. in her comment letter.

And “it is hard for people to recall when they were last vaccinated, and if that vaccination was ‘up to date,’” protested Dan Savitt with VNS Health (formerly VNS NY) in the agency’s comment letter.

Plus, “when a home health clinician is visiting a patient for the first time, a query about COVID vaccine status has the potential to increase anxiety and cause friction between the patient and the home health provider. This information can be obtained more accurately, comprehensively, and appropriately in other ways. A patient’s primary care provider could collect this information (far more Medicare enrollees visit their PCP than receive home health care each year),” Savitt suggested.

And “this measure has not been tested for validity and reliability and thus we cannot support it without knowing that it is, at minimum, feasible to report and likely to produce statistically meaningful information,” the American Hospital Association told CMS in its letter. “Furthermore, we are not clear that the conceptual construction of the measure is the best way to encourage vaccination, especially in post-acute settings where care is delivered in episodic rather than longitudinal fashion,” AHA added.

“It is possible that a post-acute care provider could have a robust effort to encourage vaccination among their patients/ residents, but still have a relatively low rate of vaccination,” AHA explained. “Cultural norms often play a large role in vaccine confidence. While post-acute providers will always seek to counsel vaccination in a culturally sensitive way, they also want to honor the choice of their patients once they have offered their clinical advice,” the trade group told Medicare officials.

“The COVID-19 vaccination is a beneficial addition to the other vaccination measure in the HH QRP. We believe it is an indirect measure of provider action since HHAs have the opportunity to encourage, as well as coordinate, vaccinations among patients. This is particularly important for HH patients, who tend to be older and thus more vulnerable to serious complications from COVID–19,” CMS responds in the final rule.

More HHQRP provisions in the rule include:

• removal of two OASIS items that are no longer necessary for collection, M0110 – Episode Timing and M2220 - Therapy Needs. “It is about time,” Krafft notes. “They stopped using both of those when PDGM started,” she points out.
• codification of the requirement that HHAs meet or exceed a data submission threshold set at 90 percent of all required OASIS assessments.
• Public reporting of the two newly adopted meaures (DC Function and COVID Vaccination), as well as Transfer of Health (TOH) Information to the Provider — Post-Acute Care (PAC) Measure (TOH-Provider) and TOH Information to the Patient — PAC Measure (TOH-Patient).