Home Health & Hospice Week

Be sure you're collecting data now or lose money in 2014.

Hospices' problems with one of the two quality measures Medicare is using hasn't stopped CMS from requiring data collection on it.

Back in July, the Centers for Medicare & Medicaid Services proposed continuing data collection on two measures for hospices: the structural measure on whether a hospice has a Quality Assessment and Performance Improvement (QAPI) program that includes at least three quality indicators related to patient care; and National Quality Forum-endorsed measure #209 on pain management.

Multiple commenters on the proposed rule expressed concern about #209. Patients who report pain upon admission, but then are unable to respond 48 hours later, should be excluded from the measure, many hospices said. Or others such as caregivers or clinicians should be able to report in their place (see Eli's HCW, Vol. XXI, No. 37).

"We ... acknowledge potential issues with measure specifications that were detailed by commenters," CMS says of the #209 comments. But "we are finalizing this proposal as proposed," the agency concludes in the 2013 home health prospective payment system final rule published in the Nov. 8 Federal Register.

Observers hope CMS will consider such changes before it publicly reports hospices' quality data, or bases payment rates on it. The agency notes in the rule that it will not publicly report data until a standardized data set tool is in place, to start. "It is essential that the data we make available to the public be meaningful data and that comparing performance between hospices requires that measures be constructed from data collected in a standardized and uniform manner," CMS says in the final rule.

For now, the 2 percent reduction to Medicare payment rates due to hospices' failure to report quality data will rely solely on whether hospices submit data, CMS notes. It won't depend on what the actual data shows or how agencies' rank in comparison to their peers. But hospices should expect that to come eventually (see related story, p. 316).

When the cuts hit: As previously finalized, CMS will reduce hospices' payment rates by 2 percent in fiscal year 2014 if they fail to collect data on the two measures during this quarter and submit it by Jan. 31 (QAPI) and April 1 (#209) of next year. Then CMS will transition to a calendar year reporting system, it finalizes in this rule.

For example: Hospices must submit data collected in all of calendar year 2013 by April 1, 2014. That data will then impact hospices' fiscal year 2015 rates, which take effect in October 2014.

CMS expects to start data collection on additional measures on CY 2015, which would be due for reporting in April 2016 and would impact payment in FY 2017 (October 2016). The agency continues to evaluate these measures for inclusion: 1617 Patients treated with an opioid who are given a bowel regimen; 1634 Pain Screening; 1637 Pain Assessment; 1638 Dyspnea Treatment; 1639 Dyspnea Screening; and 0208 Family Evaluation of Hospice Care.

Note: The final rule is at www.gpo.gov/fdsys/pkg/FR-2012-11-08/pdf/2012-26904.pdf.