Home Health & Hospice Week

CAHPS question on pain remains intact.

The federal government’s fight against opioid overuse and abuse will take a home health-specific turn in 2021.

That’s when the Centers for Medicare & Medicaid Services will eliminate one OASIS item on pain and add three more.

Out: CMS will eliminate M1242 (Frequency of Pain Interfering with Patient’s Activity or Movement) from OASIS starting in January 2021, the agency says in the 2020 final rule published in the Nov. 8 Federal Register. That’s because it’s also getting rid of the quality measure the data supports, Improvement in Pain Interfering with Activity (NQF #0177).

The Home Health Quality Reporting Program has used that pain measure since 2007, CMS notes in the rule. The National Quality Forum-endorsed, risk-ad­justed outcome measure reports the percentage of home health episodes during which the patient’s frequency of pain with activity or movement improves.

“We are removing pain-associated quality measures from our quality reporting programs in an effort to mitigate any potential unintended, overpre­scription of opioid medications inadvertently driven by these measures,” CMS explains in the final rule.

This measure is ripe for removal because “we have particular concern with quality measures that assess directly or indirectly whether or not a patient’s pain has improved, as we believe such measures may more directly incentivize over-pre­scribing of opioids,” CMS adds.

“Although we are not aware of any scientific studies that support an association between the prior or current iterations of the Improvement in Pain Interfering with Activity Measure (NQF #0177) and opioid prescribing practices, out of an abundance of caution and to avoid any potential unintended consequences,” CMS has finalized its removal after “careful consideration,” according to the rule.

M1242 is “the most subjective OASIS question,” judges Julianne Haydel with Haydel Consulting Services and The Coders.

Eliminating the pain question will also get rid of a risk area for agencies, Haydel expects. “When a nurse regularly documents pain and there are no orders to address it, it appears as though the nurse is being negligent,” Haydel tells Eli. “On the other hand, how many times can a doctor order narcotic pain relief for a patient?”

Remember: “Opiates and sedatives contribute to falls and very poor judgment,” Haydel warns. “Most of us have some sort of pain almost daily. Headaches from allergies, old injuries that cause stiff joints in the morning, etc.”

The frequency of pain interfering with activity “is not relevant to most people,” Haydel maintains. “If the pain is bad enough to impair quality of life, it will show up elsewhere in the assessment like diagnosis codes, concentration, anxiety, depression, etc.”

A number of commenters on the proposed rule appeared to agree, telling CMS they supported the eliminations.

New Pain SPADEs On Deck

A larger group of commenters, however, disagreed with the changes. “The majority of commenters did not support the proposal to remove the Improvement in Pain Interfering with Activity Measure,” CMS acknowledges in the final rule. “Several commenters stated that pain is an important concern for home health patients and that information on pain was valuable to the care team and for quality improvement. These commenters noted that pain can be a root cause of declining health and well-being and is linked to patient quality of life. Some commenters said that measuring pain improvement helps assess treatment efficacy,” CMS says.

“Pain interference remains one of the best pain assessments due to its focus not just on pain intensity but also the impact of pain on function,” said Ohio physical therapist Melinda Earnest in her comment letter.

“We agree that pain is an important concern for home health patients,” CMS tells commenters in the final rule. Many of their concerns will be addressed by three new SPADE elements on pain, CMS counters.

These items will take effect at the same time that M1242 drops off OASIS, Jan. 1, 2021. “This timeline will ensure that there is no gap in the assessment and reporting of pain for this population,” CMS says in the final rule.

Haydel praises J0510 on pain interfering with sleep as a good question. “Like narcotics, lack of sleep can cause balance problems, poor judgment, and a compromised immune system,” she notes. “Plus, people are miserable when they don’t sleep enough. It’s a quality of life thing.”

CMS also assures HHAs that they shouldn’t be aiming for patients to not use opioids at all. “When used correctly, prescription opioids are helpful for treating pain,” the agency notes. “However, effective non-opioid pain treatments are available to providers and CMS is working to promote their use.”