Home Health & Hospice Week

Will increased measures mean increased burden for home health agencies?

Medicare may have only one new measure up for adoption in 2016, but it’s just the first step in IMPACT Act implementation. In the home health prospective payment system proposed rule for 2016, the Centers for Medicare & Medicaid Services offers four IMPACT Act-related cross-setting measure areas for potential 2017 implementation:

1. Risk-adjusted potentially preventable hospital readmission rates;

2. Resource use, including total Medicare spending per beneficiary;

3. Discharge to community; and

4. Medication reconciliation.

CMS also throws out seven areas for “future measure development” beyond 2017 (see box, this page, for measure areas).

Don’t Overload Already Burdened HHAs

Implementation of the proposed IMPACT Act measures “will require additions or modifications to the OASIS assessment or the introduction of a new assessment tool for home health patients,” noted the National Association for Home Care & Hospice in its comment letter. “NAHC is concerned with the potential burden associated with measures that will require the agency to collect and report additional data.”

Do this: “Give due consideration to the burden involved for home health agencies when developing new quality measures,” NAHC urged CMS.

“CMS should balance the addition of new quality measures with the eliminating older measures that are currently part of” the Home Health Quality Reporting Program.

CMS should also employ a “transparent process for measure development that allows for multiple avenues for stakeholder input,” the trade group exhorted.

Aside from the specific measures, “we continue to urge CMS to develop and make publicly available a comprehensive plan describing how it will implement the provisions of the IMPACTAct in all of its post-acute care quality programs,” said the Nebraska Hospital Association in its comment letter. “The IMPACT Act is a multi-faceted law that will have significant operational impacts for HH agencies, long-term care hospitals (LTCHs), skilled nursing facilities (SNFs) and inpatient rehabilitation facilities (IRFs). The law’s requirements will involve changes to quality measures and the patient assessment tools used for each care setting. A comprehensive plan would enable all stakeholders to understand whether CMS’s approach works in a concerted fashion across its programs. It also would give all of the affected post-acute care providers an opportunity to plan for the potential impacts to their operations.”