Home Health & Hospice Week

Dropped measures will come with OASIS changes.

Medicare continues to focus on fine-tuning its quality reporting program for home health agencies, according to the new 2019 Home Health Prospective Payment System proposed rule.

The Centers for Medicare & Medicaid Services proposes removing seven quality measures from the Home Health Quality Reporting Program in 2021, say attorneys A. Paige Miller and Travis G. Lloyd with Bradley Arant Boult Cummings in analysis of the rule. CMS also proposes refining and adding to the factors it uses to eliminate quality measures (see box, p. 199).

Of the current 31 HQRP measures, CMS proposes not requiring reporting for these, according to the rule published in the July 12 Federal Register:

1. Depression Assessment Conducted. “Measure performance among HHAs is so high and unvarying that meaningful distinctions in improvements in performance can no longer be made,” CMS says in the rule released July 2.

“The mean and median agency performance scores for this measure in 2017 (96.8 percent and 99.2 percent, respectively) when compared to the mean and median agency performance scores for this measure in 2010 (88.0 percent and 96.6 percent, respectively) indicate that an overwhelming majority of patients are screened for depression in the HH setting,” CMS says.

OASIS impact: “If finalized as proposed, HHAs would no longer be required to submit OASIS Item M1730, Depression Screening at SOC/ROC for the purposes of this measure beginning January 1, 2020,” the rule says. “HHAs would however continue to submit data on M1730 at the time point of SOC/ROC as a risk adjuster for several other OASIS-based outcome measures.” And, “data for this measure would be publicly reported on HH Compare until January 2021.”

2. Diabetic Foot Care and Patient/Caregiver Education Implemented during All Episodes of Care. This measure also suffers from the high, unvarying performance issue, CMS notes. “The mean and median agency performance scores for this measure in 2017 (97.0 percent and 99.2 percent, respectively) when compared to ... 2010 (86.2 percent and 91.7 percent, respectively), indicate that an overwhelming majority of HH episodes for patients with diabetes included education on foot care,” CMS says. “In addition, in 2017 the 75th percentile measure score (100 percent) and the 90th percentile score (100 percent) are statistically indistinguishable from each other, meaning that the measure scores do not meaningfully distinguish between HHAs.”

OASIS impact: “If finalized as proposed, HHAs would no longer be required to submit OASIS Item 74 row a, Intervention Synopsis: Diabetic foot care at the time point of Transfer to an Inpatient Facility (TOC) and Discharge from Agency — Not to an Inpatient Facility (Discharge) for the purposes of the HH QRP beginning January 1, 2020,” CMS adds. “HHAs may enter an equal sign (=) for M2401, row a, at the time point of TOC and Discharge on or after January 1, 2020.”

However, “if finalized as proposed, data for this measure would be publicly reported on HH Compare until January 2021,” CMS says.

3. Multifactor Fall Risk Assessment Conducted For All Patients Who Can Ambulate (NQF #0537). This is another measure that suffers from high, unvarying performance.

“The mean and median agency performance scores for this measure in 2017 (99.3 percent and 100.0 percent, respectively) when compared to … 2010 (94.8 percent and 98.9 percent, respectively), indicate that an overwhelming majority of patients in an HHA have had a multifactor fall risk assessment at SOC/ROC and demonstrates the improvement in measure performance since its adoption,” according to the rule. “In addition, in 2017 the 75^th percentile measure score (100 percent) and the 90^th percentile measure score (100 percent) are statistically indistinguishable from each other.”

OASIS impact: “If finalized as proposed, HHAs would no longer be required to submit OASIS Item M1910, Falls Risk Assessment at SOC/ROC beginning January 1, 2020. HHAs may enter an equal sign (=) for M1910 at the time point of SOC and ROC beginning January 1, 2020. If finalized as proposed, data for this measure would be publicly reported on HH Compare until January 2021,” CMS says.

4. Pneumococcal Polysaccharide Vaccine Ever Received Measure. This measure’s specs don’t fully reflect current Advisory Committee on Immunization Practices guidelines, CMS says.

ACIP now recommends intervals for sequential administration of two different pneumococcal vaccines depending on patient factors including current age and age at time of previous vaccination. Therefore, this measure “no longer aligns with the current clinical guidelines or practice,” the agency concludes.

OASIS impact: If finalized, HHAs would no longer be required to submit OASIS Items M1051, Pneumococcal Vaccine and M1056, Reason Pneumococcal Vaccine not received at the time point of TOC and Discharge beginning Jan. 1, 2020.

“HHAs may enter an equal sign (=) for Items M1051 and M1056 at the time point of TOC and Discharge on or after January 1, 2020. If finalized as proposed, data for this measure would be publicly reported on HH Compare until January 2021,” the rule says.

5. Improvement in the Status of Surgical Wounds. “A more broadly applicable measure (across settings, populations, or conditions) for the particular topic is available,” CMS explains. This measure “is limited in scope to surgical wounds incurred by surgical patients and excludes HH episodes of care where the patient, at SOC/ROC, did not have any surgical wounds or had only a surgical wound that was unobservable or fully epithelialized.”

In 2016, only 13 percent of HH patients had a surgical wound at the beginning of their episode and only 36.6 percent of HHAs were able to report data on the measure for that year, CMS notes.

“In contrast, the Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short Stay) Measure (NQF #0678) and its replacement measure, Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury Measure more broadly assess the quality of care furnished by HHAs with respect to skin integrity,” CMS maintains.

OASIS impact: “HHAs would no longer be required to submit OASIS Items M1340, Does this patient have a Surgical Wound? and M1342, Status of Most Problematic Surgical Wound that is Observable at the time points of SOC/ROC and Discharge for the purposes of this measure” beginning with Jan. 1, 2020. However, HHAs would still have to submit M1340 and M1342 data at SOC/ROC as risk adjusters for several other HHQRP measures, and also at Discharge for the Potentially Avoidable Events measure Discharged to the Community Needing Wound Care or Medication Assistance that is used by HH surveyors during the survey process, CMS highlights. “If finalized as proposed, data on this measure would be publicly reported on HH Compare until January 2021.”

6. Emergency Department (ED) Use without Hospital Readmission during the First 30 Days of HH (NQF #2505). Because this measure is for patients with an acute inpatient hospitalization in the five days before the start of their home health stay, it “is limited to Medicare FFS patients with a prior, proximal inpatient stay,” CMS says.

The measure “ED Use without Hospitalization During the First 60 Days of HH (NQF #0173)” captures the ED utilization better, CMS contends. Eliminating the readmission measure (NQF #2505) in favor of the hospitalization measure (NQF #173) “will not result in a loss of the ability to measure the topic of ED utilization for HH patients,” the rule says.

This measure has no OASIS impact, but if finalized, “data for this measure would be reported on HH Compare until January 2020,” CMS adds.

7. Rehospitalization during the First 30 Days of HH (NQF #2380). The “Acute Care Hospitalization During the First 60 Days of HH (NQF #0171)” captures this information better, because it doesn’t exclude patients who didn’t have a hospital stay preceding their HH stay, CMS maintains.

As with the ED measure, if finalized, data for this measure would be publicly reported on HH Compare until January 2020.

CMS will take comments on the proposed rule until Aug. 31.

Note: A link to the proposed rule is at www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HomeHealthPPS/Home-Health-Prospective-Payment-System-Regulations-and-Notices-Items/CMS-1689-P.html.