Home Health & Hospice Week

CMS aims to reduce provider burden with new criterion.

Medicare officials have made a lot of noise about reducing providers’ regulatory burdens. While home health agencies may not feel like the Centers for Medicare & Medicaid Services is tackling their most pressing concerns, such as the face-to-face physician encounter requirement, CMS is taking burden relief action in the area of quality.

“In furtherance of the Meaningful Measures Initiative and to further align with the policies of other CMS quality reporting programs, CMS is proposing to replace our policy for removing previously adopted

HH QRP measures with eight measure removal factors,” the agency says in its fact sheet about the newly proposed 2019 Home Health Prospective Payment System rule.

CMS’s current removal factor policy, adopted in 2017, uses six criteria. CMS wants to swap those out for these seven factors it already uses in quality reporting programs for skilled nursing facilities, long-term care hospitals, and inpatient rehabilitation facilities:

1. Measure performance among HHAs is so high and unvarying that meaningful distinctions in improvements in performance can no longer be made.
2. Performance or improvement on a measure does not result in better patient outcomes.
3. A measure does not align with current clinical guidelines or practice.
4. A more broadly applicable measure (across settings, populations, or conditions) for the particular topic is available.
5. A measure that is more proximal in time to desired patient outcomes for the topic is available.
6. A measure more strongly associated with desired patient outcomes for the topic is available.
7. Collection or public reporting of a measure leads to negative unintended consequences other than patient harm.

And CMS wants to add this factor:

8. The costs associated with a measure outweigh the benefit of its continued use in the program.

Under factor 8, the provider and clinician costs CMS will consider that might outweigh any benefit include: information collection and reporting burden; complying with other HH programmatic requirements; participating in multiple quality programs and tracking similar or duplicative measures within or across those programs; and compliance with other federal and state regulations. CMS will also consider its own cost “associated with the program oversight of the measure, including measure maintenance and public display,” it adds in the rule published in the July 12 Federal Register.

Caveat: “We would remove measures based on proposed Factor 8 on a case-by-case basis,” CMS says in the rule. “For example, we may decide to retain a measure that is burdensome for HHAs to report if we conclude that the benefit to beneficiaries is so high that it justifies the reporting burden.”

Note: The 2019 proposed rule fact sheet is at www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2018-Fact-sheets-items/2018-07-02.html.