Home Health & Hospice Week

Not every drug review problem qualifies for this item — and the next-day deadline.

As expected, the Drug Regimen Review items on OASIS-C2 are giving home health agencies problems, if a new question-and-answer set from CMS is an indicator.

The Centers for Medicare & Medicaid Services has posted Q&As from in-person training it conducted back in May, and a number of questions focus on M2003 (Medication Follow-up: Did the agency contact a physician [or physician-designee] by midnight of the next calendar day and complete prescribed/recommended actions in response to the identified potential clinically significant medication issues?) and M2005 (Medication Intervention: Did the agency contact and complete physician [or physician-designee] prescribed/recommended actions by midnight of the next calendar day each time potential clinically significant medication issues were identified since the SOC/ROC?).

Question: “How should we complete M2003 if the SOC occurs on a Sunday, the registered nurse finds a medication issue, and the physician is unavailable within the 24-hour period?” a training attendee asked.

Answer: “In completing M2003, select response ‘1 — Yes’ when the two-way communication with the physician or physician designee AND completion of the prescribed/recommended actions have occurred by midnight of the next calendar day after the potential clinically significant medication issues were identified, regardless of the assessment’s day of the week or the physician’s availability,” CMS responds.

In other words, you are on the hook if the doc isn’t available to you. A number of providers complained about this very scenario in their comments on the 2017 Home Health Prospective Payment System proposed rule (see Eli’s HCW, Vol. XXVI, No. 2). The midnight-next-day timeline “is problematic because, for example, on a weekend we often will report an issue to the oncall physician but they can’t appropriately address the report because they have not been following the patient’s care,” said Providence Health & Services, in Renton, Washington, in its comment letter.

This measure “penalize[s] HHAs for something out of their control,” protested UnityPoint at Home in Iowa in its comment letter. “If a HHA admits a patient on a Saturday afternoon and notifies a physician’s office, the HHA often hears from an on-call provider that is not willing to make medication changes on behalf of a colleague causing reconciliation delay.”

But CMS didn’t not relent in the face of numerous requests to change the OASIS items and resulting quality measures. The deadline is “consistent with clinical practice when a clinically significant medication issue arises requiring intervention,” the agency said in the HH PPS final rule published in the Nov. 3, 2016 Federal Register. “This measure helps to ensure that high quality care services are furnished and that patient harm is avoided.”

Question: More attendees asked which drugs they should include in the review. “Physicians are complaining when they are informed about medication combinations the patient has been on for years,” according to one provider.

Answer: Agencies “should consider all medications that the patient is currently using,” regardless of usage length, CMS instructs.

Question: Another provider asked for elaboration on how to use “clinical judgement to determine if an issue is clinically significant,” and thus subject to the deadline.

Answer: “Whether a situation is considered a potential clinically significant medication issue is completely up to the clinical judgement of the assessing clinician,” CMS says. “This includes interpreting EMR drug review alerts.”

Don’t make more work for yourself by unnecessarily including medication events in this category when you don’t need to, CMS indicates. “It is possible for a clinician to determine the physician should be notified of an issue that does not require the timing of ‘by midnight of the next calendar day,’ and therefore the issue would not meet the definition of a potential clinically significant medication issue as defined for this item,” according to the Q&As.

Note: To see the 11 Q&As, which address issues ranging from pressure ulcer items to transfer situations, go to www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/May-2017-HHQRP-Provider-Training-Q-and-A.pdf.