Home Health & Hospice Week
Industry Blasts Proposed Quality Measures
You could have to live up to these burdensome new standards soon. Reps Target ACOVE For Criticism Industry reps heaped the most scorn on the process-based measures proposed as part of the ACOVE (Assessing Care Of Vulnerable Elders) set by Rand Corp. (items 19-25, Image). Adverse Events Are Almost as Bad There are plenty of OASIS-based outcomes on the list that agencies don't like either. OBQI Measures Riddled With Problems Even many of the outcome-based quality improvement measures (items 1-11, Image) are unfit for public reporting, reps argue. The fact that CMS is refining the OASIS questions and OBQI items through its Technical Expert Panel is proof that the measures have a long way to go, the associations maintained.
VNAA urges the forum to recommend the OBQI items on the condition that CMS resolves the stated problems with them. "A conditional recommendation by NQF could well generate the additional resources and priority needed within CMS to finalize these overdue OBQI refinements," the trade group hopes.
There's no way home health agencies should take on a host of costly, untested and flawed quality measures proposed by the National Quality Forum.
So argue industry representatives in their comments on NQF's 28 proposed quality measures for HHAs. The industry isn't taking the proposal lying down, and reps level harsh criticism at many of the measures.
NQF publicly proposed its measures in Sept-ember, and members of the quality organization will vote on finalized measures from Nov. 22 to Dec. 23. Then, the NQF Board will make its final consideration of the measures, and NQF will send a final report to Congress in February.
Federal law requires the Centers for Med-icare & Medicaid Services to adopt the quality measures for home care providers, or justify in a report why it can't (see Eli's HCW, Vol. XIII, No. 34, p. 266).
But HHAs have major problems with many of the new measures, and trade groups have put forth an effort to educate NQF members on the issues before the final vote.
No OASIS or other standard Medicare form collects most of this data, blasted the National Association for Home Care & Hospice in its Oct. 1 letter to NQF. "To add ACOVE measures on top of OASIS requirements would be excessively burdensome," NAHC warns.
CMS required NQF to propose measures that didn't place an additional reporting burden on HHAs, but the forum disregarded the requirement by using funds from outside sources. NQF should jettison the ACOVE standards, plus the hospice standards proposed by the National Hospice and Palliative Care Organization (items 26-28, Image) because they don't meet CMS' reporting burden criteria, the American Associa-tion for Homecare protests in its Oct. 5 comment letter.
And the ACOVE standards haven't even been tested in the home care setting, points out the Visiting Nurse Associations of America in its Oct. 5 comment letter. "Little was known about the standards beyond their description and no person on the [NQF home health steering] Committee had personal experience either collecting or using them," VNAA chastises.
The ACOVE measures were pilot tested only in managed care organizations, AAH adds.
And the ACOVE standards don't measure patients' outcomes, but only agencies' processes. "The ACOVE standards would constitute a step backwards as they are not outcome measures at all but rather process or 'checklist' measures," AAH argues.
Trade groups take special issue with the adverse events included in the proposal (items 13-18, Image). These OASIS items, used as part of the outcome-based quality monitoring (OBQM) system, are flags only for potential problems, VNAA stressed in its letter. The measures "only have meaning when specifically investigated and may easily be misinterpreted," VNAA warns.
And adverse events aren't risk adjusted to compensate for the acuity of an agency's patient population, NAHC points out. "Without risk adjustment, home health agencies that serve the poorest, oldest, and sickest patients will have higher rates of adverse events for reasons beyond their control."
VNAA members often find their adverse events are due to simple coding errors, the association says. And frequently they "do NOT reflect inappropriate care when placed in the context of the specific patient situation," VNAA argued.
The NQF home health steering committee initially rejected the OBQM items as measures, which is very telling, VNAA says.
Specific problems with measures include:
Despite the specific reservations enumerated, all the associations endorse the idea of publicly reported quality measures for home care providers. However, they urge caution to make sure the most appropriate ones are implemented. "There is more to be gained at this early point in quality measurement from endorsing a smaller list of the most sound measures than a more exhaustive list that is inclusive of controversial or poorly understood measures," VNAA offers.
The effectiveness of the trade groups' and other industry comments remain in question. NQF may turn a deaf ear to the comments, chalking them up to an effort to shirk accountability rather than offer legitimate concerns, industry reps tell Eli. 
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