Home Health & Hospice Week

The buck stops with the board of directors, study says.

You have a new reason to take stock of your quality improvement process, even if pay for performance isn't waiting on your doorstep.

The HHS Office of Inspector General issued a new guide, "Corporate Responsibility and Health Care Quality: A Resource for Health Care Boards of Directors," Sept. 10. The OIG published it in partnership with the American Health Lawyers Association.

The report should serve as a wake-up call for the boards of directors of home health agencies, AHLA's Peter Leibold tells Eli.

"Boards tend to focus on the financial stability of the organization," says Leibold. But that limited view won't pay off in the future. In fact, financial stability is fast becoming closely related to quality of care, say experts.

The Centers for Medicare & Medicaid Services "is moving from a passive payer to an active purchaser of quality health care services," says attorney Janice Anderson, partner with Foley & Lardner in Chicago. "You can no longer separate quality from financial stability."

Count The Reasons

Besides moving Medicare toward pay for performance for home health and other provider types, CMS and other federal agencies are scrutinizing more closely how health care organizations monitor and improve care quality.

Evidence: The Aug. 22 final rule on refinements to the home health prospective payment system adds two new publicly reported quality measures in 2008. That's in addition to the 10 already reported on Home Health Compare, for a total of 12 measures, noted CMS' Randy Throndset in the Aug. 29 Open Door Forum for home care providers (see Eli's HCW, Vol. XVI, No. 31).

What are the biggest factors driving a need for stepped up quality improvement? The report stresses these three:

1. Enforcement action. Nursing homes historically have been enforcement targets, says Anderson, but that's changing fast. "The federal government is casting a wider net," she says.

Though the report does not mention enforcement actions against HHAs, it holds up examples that should serve as a caution to all providers.

Profit drain: For example, a Colorado rehabilitation center has filed a $1.9 million civil False Claims Act settlement to resolve allegations that it provided "worthless services to patients, resulting from systemic understaffing at the facility, where deficient services and abuse caused six patient deaths," according to the report.

2. P4P. "Pay-for-performance programs are becoming common among both public and private payors," the report notes. And even before Medicare adopts such a payment system for home health, agencies should be aware quality can affect reimbursement in other ways.

Example: Quality breaches can lead to a suspension of billing privileges under government programs including Medicare and Medicaid.

3. Consumer demand. Consumers want greater transparency and information about the care they receive, the OIG and AHLA note in the report.
 
"Educated consumers are asking for high quality of care," says Leibold.

Tap This Resource

Home health agencies have made sound gains in their quality improvement programs, suggests Sean Hunt of Quality Insights of Pennsylvania, the quality improvement organization contracting with CMS to help HHAs nationwide reduce avoidable acute care hospitalizations.

"Many more have formal QI processes in place than not," says Hunt. Still there's room for improvement. Only about one in four HHAs currently works with a QIO, she reports.

"Many providers are just becoming aware of the responsibility" to improve quality, Anderson says. 

Note: To view or download the report, go to www.oig.hhs.gov.