Home Health & Hospice Week

You could have to live up to these burdensome new standards soon.


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. 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).

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. Adverse Events Are Almost as Bad There are plenty of OASIS-based outcomes on the list that agencies don't like either.

Trade groups take special issue with the adverse events [...]