Home Health & Hospice Week

Plus: Watch for new OASIS item on diagnoses if proposal adopted.

Flashier provisions in the 2016 proposed PPS rule, such as Value-Based Purchasing and reimbursement rate cuts, are catching the lion’s share of attention. But quieter proposals in the rule will have a big impact too.

Case in point: “We are proposing the implementation of the quality measure NQF #0678, Percent of Residents or Patients with Pressure Ulcers that are New or Worsened (Short Stay) in the [Home Health Quality Reporting Program] as a cross-setting quality measure to meet the requirements of the IMPACT Act for the CY 2018 payment determination and subsequent years,” the Centers for Medicare & Medicaid Services said in the home health prospective payment system proposed rule released July 6 (see Eli’s HCW, Vol. XXIV, No. 24).

“This measure reports the percent of patients with Stage 2 through 4 pressure ulcers that are new or worsened since the beginning of the episode of care.” Multiple commenters on the rule expressed support for focusing on the area of pressure ulcers. Implementing the measure will “help facilitate best practice measures for prevention of pressure ulcers and appropriate care for pressure ulcers in all settings,” said Barbara Dale of Tennessee in her comment letter. “Pressure ulcers in the home ARE devastating to patients and caregivers alike.”

Bonus: CMS will draw the data from this measure from items already collected in OASIS — M1308 (Current Number of Unhealed Pressure Ulcers at Each Stage or Unstageable) and M1309 (Worsening in Pressure Ulcer Status Since SOC/ ROC). Data for risk adjustment also is already collected via OASIS, CMS notes in the rule. OASIS items used would most likely include M1850 (Activities of Daily Living Assistance, Transferring), M1620 (Bowel Incontinence Frequency), M1016 (Diagnoses Requiring Medical or Treatment Change Within past 14 Days), M1020 (Primary Diagnoses), and M1022 (Other Diagnoses). CMS began collecting the M1309 data last January, in anticipation of coming IMPACT Act measures, the agency notes in the rule.

The Nebraska Hospital Association “appreciates that the agency has chosen a measure that uses data HH agencies already collect,” the trade group said in its comment letter.

Sneak peek: But there would be some changes to the integumentary status items that would support this measure, and CMS would renumber M1308 and M1309 in implementing the revisions. See a draft of the changes at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/OASIS-January_2017_July2015.pdf.

CMS would also add an M item on “Active Diagnoses.” The new M item would ask for active diagnoses in the last seven days and instruct agencies to check one or both boxes that apply: “1 — Peripheral Vascular Disease (PVD) or Peripheral Arterial Disease (PAD)” and/or “2 — Diabetes Mellitus (DM) (e.g., diabetic retinopathy, nephropathy, and neuropath).” The item includes the instruction that “Diagnoses listed in parentheses are provided as examples and should not be considered as all-inclusive lists.”

Providers agreed on needed changes to the OASIS revisions, especially for the height and weight items (see story, p. 300). Other feedback included:

• M1308 and M1309. The proposed formatting of M1308 “with a second section for each pressure ulcer staging category will be easier for the clinicians to understand than the previous table format used in OASIS-C,” praised St. Joseph’s Home Care in New York. But it seems unnecessary “to collect data via both M1309 AND M1308 sections A2, B2, C2, etc.,” the agency said in its comment letter. “The wording is similar enough that I am concerned about creating confusion for the clinicians.” Combining the items may be advisable.

Collecting M1308 at recert would “provide a mechanism for internal monitoring of the pressure ulcers for active patients,” St. Joseph also suggested.

• Other wounds. In addition to pressure ulcers, “we feel strongly that other types of wounds deserve equal assessment and consideration when determining the clinical and functional status of the patient,” said AW Healthcare in Missouri.
• Diagnoses. “We do like having active diagnoses that are typically barriers to good outcomes within the document,” AW said. But the “listshould be broadened and clarification [given] as to whether the item is referencing new diagnoses or symptomology of the disease processes is required.”

Stay tuned: You can see whether CMS heeds any of the industry’s advice when the 2016 final rule comes out, which is expected to be very soon.