Home Health & Hospice Week

Revisions will take public reporting to 'a whole new level,' expert says.

Medicare's focus on quality of care is front and center in the proposed hospice payment rule for fiscal year 2019.

The hospice benefit has gone through some really big changes in recent years, ranging from payment reform to cost reporting requirements to public reporting of quality data. Thankfully, while the new payment rule contains many provisions, none of them are of the same huge magnitude, notes Judi Lund Person with the National Hospice & Palliative Care Organization.

It's a welcome change to have a year without "earth-shattering" program revamps afoot, Lund Person tells Eli.

However, hospices still must keep abreast of the many developments either in progress or on the horizon for the industry, Lund Person urges. A good number of those in this year's rule pertain to the Hospice Quality Reporting Program, including these Hospice Compare provisions:

• Hospice Compare Streamlining. It's not news that the Centers for Medicare & Medicaid Services will display the quality measure "Hospice and Palliative Care Composite Process Measure - Comprehensive Assessment at Admission" on Hospice Compare. CMS finalized that decision in its FY 2017 hospice payment rule.

However, in the new 2019 rule, CMS confirms that it expects to begin publicly reporting the measure in fall 2019. And CMS reveals that when it posts this composite measure, it will reduce the visibility of the seven currently-displayed measures that comprise it (see box below). "The reporting of these 7 component measures alongside the composite measure may be redundant and may result in confusion and burden for users," CMS says in the rule.

"However, we also recognize that the component measures may be useful to some individuals using Hospice Compare. Therefore, while we intend to no longer directly display the 7 component measures as individual measures ... once the composite measure is displayed, we would still provide the public the ability to view these component measures in a manner that avoids confusion on Hospice Compare."

How it will work: "We plan to achieve this by reformatting the display of the component measures so that they are only viewable in an expandable/collapsible format under the composite measure itself, thus allowing users the opportunity to view the component measure scores that were used to calculate the main composite measure score," CMS explains.

This change seems good for both hospices and potential patients, Lund Person says. It should eliminate confusion and motivate hospices to focus on all seven components of the composite measure.

• Visit Measure Scheduled. While the composite admission measure has a fall 2019 due date, CMS gives a more general time frame of 2019 for the other measure finalized in the 2017 rule - "Hospice Visits when Death is Imminent."

Reminder: Data collection for the measure, which is a two-part Hospice Item Set-based metric that assesses hospice skilled staff visits to patients and caregivers in the last week of life, began April 1, 2017. Part 1 of the measure assesses the percentage of patients receiving at least one visit from registered nurses, physicians, nurse practitioners, or physician assistants in the last 3 days of life; part 2 measures the percentage of patients receiving at least two visits from medical social workers, chaplains or spiritual counselors, LPNs, or hospice aides in the last 7 days of life.

• Public Use Files. The rule also announces CMS's intentions to publish information from Medicare's Public Use Files and other public CMS sources on Hospice Compare. The agency does so for other Compare sites such as those for nursing homes and end-stage renal disease providers, it says. The PUFderived data would have its own section on the website and would be based on adjudicated claims.

For example: Info displayed may include items like percent of days a hospice provided routine home care (RHC), averaged over multiple years; percent of primary diagnosis of patients served by the hospice (cancer, dementia, circulatory/heart disease, stroke, respiratory disease) which would be a calculation of the total number of patients by diagnosis divided by the total number of patients served; and site of service (long-term care or non-skilled nursing facility, skilled nursing facility, inpatient hospital) with a notation of yes, based on whether the hospice serves patients in that facility type, CMS offers.

"While these types of information are not quality measures, they capture information that many consumers seek during the provider selection process and, therefore, will help them to make an informed decision," CMS reasons in the rule.

"For example, information about conditions treated by the hospice could show a patient with dementia if a hospice specializes or is experienced in caring for patients with this condition. Additionally, if a patient has a specific need, like receiving hospice care in a nursing home, information from the PUF could help this patient or their loved ones determine if a provider in their service area has provided care in this setting," the rule says.

CMS adds that "analyses of the PUF data show variation between hospice providers in the data points outlined above, indicating that these data points could be meaningful to consumers in comparing services provided by hospices based on the factors most important to them."

Bottom line: "PUF data can serve as one more piece of information, along with quality of care metrics from the HIS and CAHPS® Hospice Survey, to help consumers effectively and efficiently compare hospice providers and make an informed decision about their care in a stressful time," CMS concludes.

Using PUF and other data will take public reporting to a "whole new level," Lund Person expects. It, and the other Compare changes likely will make hospice care much more transparent, she believes.

Don't be surprised to see display of PUF data go up quickly, Lund Person adds - perhaps even some time this year.

You can see what PUF data may be up for display in the file at www.cms.gov/Research-Statistics-Data-and-Systems/Statistics-Trends-and-Reports/Medicare-Provider-Charge-Data/Hospice.html.

Note: For more quality program changes in the rule, see a future issue of Eli's Home Care Week.