NAHC Submits Comments on Standardized Data Set items
September 23, 2016 09:48 AM
The National Association for Home Care & Hospice submitted comments on the collection of standardized assessment-based data items developed under the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) on the domains of: cognitive function and mental status; special services, treatments, and interventions; medical conditions and co-morbidities; and impairments. The standardized assessment-based data items were developed for the Long-Term Care Hospital, the Inpatient Rehabilitation Facility, the Skilled Nursing Facility, and the Home Health Agency settings.
CMS sought public comments on whether items have the potential for improving quality, the utility of the items for describing case mix, the feasibility of the items for use in post-acute care settings, and the validity of the items. The public comment period ended September 12, 2016.
In general, NAHC believes the proposed standardized data set items under the domains for cognitive function and mental status; special services, treatments, and interventions; medical conditions and co-morbidities; and impairments have potential for improving quality, meet validity criteria, are feasible for use in the home health care setting, and are important elements for determining case mix. However, NAHC has concerns regarding the potential for duplication and/or overlap with current OASIS assessment items and the implications for replacing or altering OASIS items.
OASIS has various applications for home health agencies (i.e. payment, quality measures, Star Rating and home health value based purchasing). Almost all of the OASIS items impact one or more of these applications either directly or through risk adjustment for the quality measures. CMS must consider these applications with any modification to the OASIS assessment instrument. The risk adjustment model and/or measure specifications for the impacted measures will need to be revised.
NAHC is also concerned that items will continue to be added to the OASIS data set instrument to meet the requirements of the IMPACT Act, which could result in a lengthy assessment tool that will become very burdensome for agencies to administer.
CMS has also announced an opportunity for public comment on a post- acute care cross setting quality measure under the IMPACT Act for Falls with Major Injury. The measure addresses the percent of patients experiencing one or more falls with major injury during a home health episode. The comment period opened Sept. 19, 2016 and closes Oct.14, 2016. More information on the can be found here.