Home Health & Hospice Week

Plus: Difficulty accessing star rating preview reports riles HHAs.

The 192-page home health final rule for 2022 contained a lot of changes from Value-Based Purchasing to OASIS-E implementation, so if you missed a change to M1860 scoring, you weren’t alone.

M1860 Ambulation/Locomotion assesses “Current ability to walk safely, once in a standing position, or use a wheelchair, once in a seated position, on a variety of surfaces.” Included among the six responses are “2 – Requires use of a two-handed device (for example, walker or crutches) to walk alone on a level surface and/or requires human supervision or assistance to negotiate stairs or steps or uneven surfaces” and “3 – Able to walk only with the supervision or assistance of another person at all times.”

Old way: In the 2020 home health final rule published in November 2019, the Centers for Medicare & Medicaid Services assigned nine points for response 2 and eleven points for response 3.

New way: In the 2022 final rule, CMS revised the points awarded to seven points for response 2 and six points for response 3, reversing which response gets more points. That change took effect Jan. 1.

CMS has received questions on the matter, an agency official acknowledged in the Feb. 24 Home Health Open Door Forum. It’s been even more confusing because in the 2022 proposed rule, CMS had both responses listed at six points. M1860 response 2 is the only OASIS item that changed case mix points between the proposed and final rules. (See the 2020 finalized points in Table 8 at https://www.govinfo.gov/content/pkg/FR-2019-11-08/pdf/2019-24026.pdf, the 2022 proposed points in Table 13 at https://www.govinfo.gov/content/pkg/FR-2021-07-07/pdf/2021-13763.pdf, and the finalized 2022 points in Table 2 at https://www.govinfo.gov/content/pkg/FR-2021-11-09/pdf/2021-23993.pdf.)

“The points … listed for responses 2 and 3 in Table 2 of the calendar year 2022 final rule are correct,” the CMS source confirmed in the forum.

“There may be times in which the resources used for certain OASIS items associated with the functional impairment will result in a seemingly inverse relationship to the response recorded,” the CMS official explained. “However, this is a result of the direct association between the responses recorded on the OASIS item and the actual resource use,” she said.

Other home health issues raised in the forum include:

• iQIES reports. CMS released Care Compare Preview Reports and Star Rating Preview Reports for the April refresh shortly before the forum. But in the call, multiple HHAs reported problems accessing them. Another agency reported a problem finding its Quality Assessments Only (QAO) report in iQIES.

The reports are supposed to be available in agencies’ iQIES folders, the CMS official said.

“iQIES is not a friendly place to find your reports,” one HHA caller told CMS. “Is there a better way to get these reports?” she asked. She also noted “they were a lot better in QTSO.”

The CMS rep said the agency will consider feedback and take a look at providing better directions on accessing the reports.

• Care Compare. Care Compare was previously re­porting incorrect services provided for some HHAs, but CMS has resolved that problem, the source related.

And while assessment-based data on Care Compare began refreshing in January, claims-based data updates are still on hold. Claims-based home health data should begin appearing on Care Compare again in July, CMS expects.

Don’t forget the April refresh will see two new OASIS-based measures added for HHAs — Percent of Residents Experiencing One or More Falls with Major Injury; and Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function.

• CAHPS. If you plan to submit a request to be exempted from CAHPS patient survey requirements in 2021 due to size, that exemption form is due March 31, a CMS staffer reminded forum attendees. And the next deadline to submit CAHPS survey data is April 21, she added.

HHAs considering changing CAHPS vendors should first contact CAHPS contractor RTI for assistance with the process, she said.

• OASIS streamline. One HHA asked if CMS is considering whittling OASIS to just the items used for risk, payment, and quality purposes. A CMS official said no, but encouraged the agency to submit such ideas in comments on OASIS-E. The comment period for the new OASIS update ends April 11 (see story below).