NAHC Submits Comments on Potentially Preventable Readmission Measure
November 19, 2015 10:06 AM
As required by the Improving Post-Acute Care Transformation (IMPACT) Act, the Centers for Medicare & Medicaid Services is working to develop a potentially preventable readmissions (PPR) measure for multiple settings, which includes skilled nursing facilities (SNF), Inpatient rehabilitation facilities (IRF), long term care hospitals (LTCH), and home health agencies (HHA).
The measure is claims-based and reflects readmission rates for patients who are readmitted to a short-stay acute-care hospital or an LTCH with a principal diagnosis considered to be unplanned and potentiallypreventable within a 30-day window following discharge from the PAC settings.
In the report, the contractor acknowledges there is limited evidence of potentially preventable readmissions (PPR) for post-acute care (PAC). Therefore, the list of potentially preventable conditions includes those identified as Ambulatory Care Sensitive Conditions developed by the Agency for Health Care Research and Quality.
The National Association for Home Care & Hospice (NAHC) has concerns regarding applying to PAC settings conditions developed for the ambulatory care setting. Patients admitted to post acute care typically have a more complex clinical profile than those patients receiving services in an ambulatory care setting.
The PPR condition list was developed using the International Classification of Diseases (ICD)-9 diagnoses codes; however, the measure will be implemented using claims with ICD-10 diagnoses codes. It is reasonable to assume that the PPR conditions list will be considerably more complex and may alter the validity of several of the diagnoses included in the measure.
Although the developers address the relationship of the proposed PPR measure with the current 30 day re-hospitalization measure for home health agencies (NQF #2380 Re-hospitalization during the First 30 Days of Home Health), it is unclear how the current 30 day re-hospitalization and the 60 day acute care hospitalization measure for home health will be aligned with the proposed PPR measure. The timelines for the current measures might overlap with the proposed PPR measure and all three measures track hospitalizations.
The developers plan to include sociodemographics as a variable for risk adjustment, which NAHC strongly supports. NAHC believes the risk adjustment model should also include variables to address income, caregiver support, and prior PAC stays.
To view the Potentially Preventable Hospital Readmission Measures for Post-Acute Care measure specifications click here
To view NAHC’s comments click here.