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Home Health & Hospice Week

Quality:

Watch Out For 2 Forthcoming HOPE-Based Quality Measures

Published on Fri Apr 21, 2023

Plus: IDR proposal should be in home health rule with SFP provision.

Medicare hasn’t even finalized the HOPE assessment tool yet, but it’s already making plans for the data the patient assessment tool will produce.

In its April 19 Open Door Forum for home health and hospice providers, the Centers for Medicare & Medicaid Services ran down the list of quality-related provisions includes in its fiscal year 2024 hospice proposed rule published in the April 4 Federal Register.

Among those provisions is the Hospice Outcomes and Patient Evaluation tool. After national beta testing wrapped up in October 2022, hospices thought they may see a proposal to finalize HOPE in this proposed rule. But that's not case.

However, “we continue HOPE development,” CMS notes in the rule. “As CMS proceeds with the refinement of HOPE, we will continue to engage with stakeholders through sub-regulatory channels,” the agency adds.

CMS offers no concrete dates, but says it “will use field test results to create a final version of HOPE to propose in future rulemaking for national implementation.”

Hospices that are worried about the burden HOPE may present can find at least a little reassurance on that front in the rule. “The standardized patient assessment data elements for certain post-acute care providers required under the IMPACT Act of 2014 are not applicable to hospices,” CMS acknowledges.

However: “It would be reasonable to include some of those standardized elements that appropriately and feasibly apply to hospice to the extent permitted by our statutory authority,” CMS maintains in the rule. “Many patients move through other providers within the healthcare system to hospice. Therefore, considering tracking key demographic and social risk factor items that apply to hospice could support our goals for continuity of care, overall patient care and well-being, development of infrastructure for the interoperability of electronic health information, and health equity,” the agency concludes.

And CMS is already making plans for how it will use HOPE data.

“CMS intends to develop at least two HOPE-based quality measures,” a CMS official noted in the April 19 forum: Timely Reassessment of Pain Impact and Timely Reassessment of NonPain Symptom Impact.

Of course, CMS plans have been known to change, so hospices should stay tuned to see how those work out, observers note.

Other hospice topics addressed in the forum include:

  • CAHPS testing. CMS tested a shorter CAHPS survey and one administered via the web and other mode combinations, the CMS speaker recounted in the forum.

“Fifty-six large hospices participated in the mode experiment, representing a range of geographic regions, ownership, and past performance on the CAHPS Hospice Survey,” CMS says in the proposed rule. “A total of 15,515 decedents/caregivers were randomly sampled from these hospices,” according to the rule.

Findings from the test included that the mail-telephone combo yielded the highest response rate at 45.3 percent, but web-mail was close behind at 39.7 percent.

CMS isn’t proposing any changes to the CAHPS survey at this time, the CMS official emphasized.

Instead, “CMS will use mode experiment results to inform decisions about potential changes to administration protocols and survey instrument content,” the rule says. “Potential measure changes will be submitted to the Measures Under Consideration (MUC) process in 2023 and may be proposed in future rulemaking.”

  • SFP. While some hospices were expecting a Special Focus Program proposal in this rule, the CMS staffer confirmed that it will appear in the home health proposed rule instead.
    The home health rule will also include a proposal for an informal dispute resolution process for hospices, the CMS speaker said. CMS didn’t mention the IDR proposal, which hospices have long asked for, in the hospice proposed rule.
    “We were hoping that it would be” included in the home health rule, notes Theresa Forster with the National Association for Home Care & Hospice. “It’s something that we’ve been pushing for,” Forster tells AAPC.

Note: The 36-page hospice proposed rule is at www.govinfo.gov/content/pkg/FR-2023-04-04/pdf/2023-06769.pdf. CMS will accept comments on the rule until May 30.

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