NQF Issues Preliminary Recommendations for the HHQRP
January 7, 2016 10:08 AM
The National Quality Forum (NQF), Measure Application Partnership (MAP) has issued its preliminary recommendations on the Centers for Medicare & Medicaid Services (CMS) measures under consideration and is seeking input from the public.
The MAP is a multi-stakeholder partnership that guides the Department of Health and Human Services (HHS) on the selection of performance measures for federal health programs. Each year CMS submits to the MAP a list of quality measures under consideration for implementation in the various federal healthcare quality reporting programs. The list submitted this year included six quality measures for the home health quality reporting program (HHQRP).
Several of the measures reviewed by the MAP during this cycle addressed the following Improving Medicare Post-Acute Care Transformation (IMPACT) Act measure domains:
Resource use measures, including total estimated Medicare spending per beneficiary (MSPB);
Discharge to community; and
All-condition risk-adjusted potentially preventable hospital readmissions rates.
One new measure related to fall risk and one new measure for improvement in dyspnea were also included for review for the HHQRP.
Five of the six measures for home health quality reporting received a preliminary recommendation to encourage continued development; one measure did not receive support by the MAP.
The six measures for the HHQRP and the MAP preliminary recommendations with comment highlights are as follows:
Encourage Continued Development
Drug regimen review:
The MAP members had several concerns with this measure. Members noted the challenge of defining some of the measure components, specifically “a clinically significant issue. The members asked for greater clarity on defining the drug regimen review process and greater emphasis of the inclusion of non-prescription medication (including supplements). MAP members also raised some concerns about the feasibility of this measure and noted the need to clarify the roles of the interdisciplinary team.
The MAP members noted the potential for unintended consequences. In particular, the group raised concerns about issues of premature discharges. Members also noted the need to consider risk adjustment for severity and socioeconomic status.
Falls risk composite process measure:
The MAP members noted that this composite measure addresses falls risk and related clinical intervention assessments, which are considered safety measures and meet the goals of the HHQRP.
Potentially Preventable 30-Day Post-Discharge Readmission Measure for Home Health Quality Reporting Program (Required under the IMPACT Act)
The MAP members raised concerns about potential overlap between other readmission measures and that this may introduce multiple penalties for the same readmission. The members asked for greater clarity about the definition of a potentially preventable readmission. Members also raised concerns about this measure for the home health setting, especially as the patient may not be under the care of the home health agency immediately post-discharge.
Discharge to Community-Post Acute Care (PAC) Home Health Quality Reporting Program (Required under the IMPACT Act)
The MAP members noted that available discharge codes and coding practices could cause confusion about the results of this measure and could also introduce validity concerns. The need for greater clarity about the intent of this measure, especially how they may impact patients and consumers was addressed. The MAP members also raised concerns about the multiple ways that readmissions are being measured and noted that a provider could potentially be penalized multiple times for the same occurrence. Further, the MAP members noted concerns about the risk adjustment of this measure, particularly for the home health setting and the need to appropriately risk adjust the measures to avoid unintended consequences
Do Not Encourage Continued Development
Improvement in Dyspnea in Patients with a Primary Diagnosis of Congestive Heart Failure, Chronic Obstructive Pulmonary Disease and/or Asthma
The MAP members disagreed with the denominator approach of focusing on specific populations and encouraged a return to a broader population approach. The members noted that dyspnea is an important quality of life issue to patients across post-acute care settings and should be a focus of improvement for all suffering from the condition.
Many of the concerns expressed by the MAP members are the same concerns the National Association for Home Care & Hospice (NAHC) has regarding several of the proposed measures. NAHC is pleased that the MAP has exercised thoughtful consideration in their deliberations and will continue to follow the measure approval process.
The MAP also reviewed several quality measures for implementation in the hospice quality reporting program that will be addressed in a separate NAHC report article.
To review the recommendations in more detail and to submit comments go here.
Public comments are due January 12, 2016.