NAHC Comments on Public Display of Survey Reports, Use of Electronic Signatures for Cost Report Submission, and End-of-life Quality Measures
June 16, 2017 04:11 PM
In mid-April, the Centers for Medicare & Medicaid Services (CMS) issued a proposed regulation: Hospital Inpatient Prospective Payment System for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Fiscal Year 2018 Rates; CMS-1677-P, which contained a number of provisions relevant to various types of Medicare providers. The National Association for Home Care & Hospice (NAHC) recently submitted a comment letter on the rule that addressed three issues:
A proposal to permit Medicare providers to utilize electronic signatures for submission of their cost report certification and settlement summary,
A proposal to potentially utilize four end-of-life care measures for cancer patients as part of the Hospital Inpatient Quality Reporting Program, and
A proposal to require national accrediting organizations to make all Medicare provider or supplier final accreditation survey reports (including statements of deficiency findings) and acceptable Plans of Correction (PoC) for the most recent three years publicly available on its website (see previous NAHC Report coverage here).
In its letter, NAHC supports CMS’ proposal to permit Medicare providers to utilize electronic signatures for submission of cost report certification and settlement summaries, but comments that additional action should be taken to further reduce current regulatory burdens related to existing processes for submitting cost reports, including:
Establishment of a means by which preparers of cost reports may, with the approval of and at the request of the provider, submit the cost report directly to the MAC on behalf of the provider,
Provide clarification on how Medicare Administrative Contractor (MAC) systems would link cost reporting documents, and
Provide clarification that the individual signing the certification statement signature is not limited to the provider’s Administrator of Chief Financial Officer.
NAHC’s letter also endorses CMS’ proposed consideration of four end-of-life care measures for cancer patients for use in the Hospital Inpatient Quality Reporting Program, and expresses support for development of similar measures related to other key mortality diagnoses.
Finally, NAHC’s letter discusses CMS’ proposal to require national accrediting organizations to publicly report, via their websites, accreditation survey information and related materials for accredited providers for the most recent three years. As part of its comments, NAHC acknowledges the importance of making reliable information on providers available to the public at large, but points out that existing inconsistencies in federal law and regulations related to public availability of survey reports must be reviewed and reconciled before CMS can consider moving forward with its proposal as put forth. Further, NAHC’s letter notes that existing requirements related to the public display of state-conducted survey reports and PoC are inconsistent with CMS’ proposal related to accrediting organizations. NAHC also notes that disclosure of survey reports can be misleading as they represent a “snapshot in time” and may be misleading or confusing to consumers and others. NAHC points out that quality COMPARE sites and Star Ratings may provide more meaningful information to consumers than would the highly technical survey reports.
A copy of NAHC’s letter and referenced attachments are available here. Special thanks to members of NAHC’s Home Health and Hospice Financial Managers Association, including Mark Sharp (BKD), Dave Macke (VonLehman), Ted Cuppett (The Health Group), Tom Boyd (Simione), Maureen Laskowski (Simione) and Gary Massey (Clifton Larson Allen) for their insights and assistance with comments on issues related to use of electronic signatures on cost report certification and settlement summaries.