CMS Open Door Forum Explores Home Health, Hospice Issues
August 11, 2017 09:38 AM
During the August 9, 2017, Home Health, Hospice and DME Open Door Forum (ODF) Centers for Medicare & Medicaid Services (CMS) representatives provided updates or reminders on the issues that follow. A recording of the ODF will be accessible beginning at 5 p.m. on Wednesday, August 9, for two days. To access the recording, please call 1-855-859-2056 and use Conference ID: 60574200. The date of the next ODF is To Be Announced.
Home Health Prospective Payment System (HHPPS):
The proposed rule for calendar year (CY) 2018 payment rate update include a 1% market basket index increase and a -0.97 case mix weight change adjustment that was finalized in the 2016 payment rate update rule. The payment rates for home health agencies are reduced by .9% for CY 2018 and in addition, the 3% rural add-on sunsets in CY 2018. The proposed policies included in the rule would result in a 0.4 percent decrease (-$80 million) in payments overall to HHAs in CY 2018.
Home Health Grouping Model (HHGM). CMS is proposing to implement case-mix methodology refinements and a change in the unit of payment from a 60-day episode of care to a 30-day period of care, effective for home health services beginning January 1, 2019. The proposed HHGM model relies more heavily on clinical characteristics and other patient information, while eliminating therapy service use thresholds that are currently used to case-mix adjust payments under the HH PPS. This includes proposed changes in the episode timing categories, the addition of an admission source category, (institutional or community) the creation of six clinical groups used to categorize patients based on their primary reason for home health care, revised functional levels and corresponding Outcome and Assessment Information Set (OASIS) items, the addition of a comorbidity adjustment, and a proposed change in the Low-Utilization Payment Adjustment (LUPA) to use the 10th percentile value of visits to create a payment group specific LUPA threshold with a minimum threshold of at least 2 for each group.
Home Health Value Based Purchasing (HHVBP) Model. CMS is proposing to amend the HHVBP model by increasing the minimal threshold for Home Health Care Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) measures to 40 completed surveys, and to remove the OASIS-based measure, Drug Education on All Medications Provided to Patient/Caregiver during All Episodes of Care, from the set of applicable measures beginning with performance year (PY) 3. CMS is also soliciting public comments on composite quality measures for future consideration.
One Clinician Rule. CMS is modifying the instructions for the “one clinician” rule when conducting OASIS assessments beginning January 1, 2018. According to the revised OASIS User Manual, only one clinician may take responsibility for accurately completing a comprehensive assessment. However, for all OASIS data items integrated within the comprehensive assessment, collaboration with the patient, caregivers, and other health care personnel, including the physician, pharmacist, and/or other agency staff is appropriate and would not violate the one clinician convention. When collaboration is utilized, the assessing clinician is responsible for considering available input from these other sources and selecting the appropriate OASIS item response(s) within the appropriate timeframe and consistent with data collection guidance.
Home Health Quality Reporting Program (HHQRP). CMS is proposing to eliminate or modify 35 OASIS items not required for quality measures, payment, survey, HHVBP or care planning. The list of data items can be found on the CMS Home Health Quality Initiative page.
In addition, CMS is proposing three new quality measures and several new standardized assessment data items in accord with the Improving Medicare Post-Acute Care Transformation Act (IMPACT Act). Collection for the mew assessment data would begin January, 2019 for the 2020 HHQRP. For a detailed description of the proposed changes to the HHQRP click here for a NAHC Report article that was published on August 3, 2017.
Further, CMS is proposing processes for requesting reconsideration of determinations regarding compliance with pay-for-reporting requirements, as well as a process for providing exceptions to these policies and extensions to reporting timeframes.
The October, 2017 refresh for home health measure reporting will post the same data for the OASIS based measures as was reported in July, 2017. The claims based and HHCAHPS measures reported in the October, 2017 refresh will reflect updated data. This is necessary to accommodate the new measure review and correction process. Reporting of the OASIS, claims based, and HHCAHPS data will be realigned for the January, 2018 refresh.
The deadline for submission of reconsiderations related to the determination that a hospice has failed to meet the Hospice Quality Reporting Program (HQRP) submission requirements affecting the FY2018 payment year is August 17. For additional information, please go HERE.
NEWLY RELEASED — CMS announced that registration is now open for the conference call, “Reporting Hospice Quality Data: Tips for Compliance,” scheduled for Wednesday, September 20, 2017, from 1:30 to 3 p.m. EASTERN. Interested stakeholders may register HERE for Medicare Learning Network events, including this call.
During this call, attendees can learn more about:
HIS and CAHPS® submission requirements
Reasons for noncompliance and how to address them
Timelines for data submission and compliance determinations
Resources for success, including how to access important websites and helpdesks
A question and answer session follows the presentation.
CMS staff also reminded hospice providers that August 9 is the most recent deadline for submission of Hospice CAHPS data (for first quarter 2017 decedents). Hospice providers should check with their vendors to ensure that submission was timely and may also check their submission reports. For additional information, please go HERE.
CMS also reminded providers that the participation exemption for size form is available on the Hospice CAHPS Website HERE (and will remain available through the end of the year). Hospices must apply annually for the exemption. Finally, vendors, subcontractors and other interested stakeholders (including providers) are reminded that CMS has scheduled the 2017 Hospice CAHPS vendor training for September 27, 2017. The CAHPS Hospice Survey Training session is required for all survey vendors approved (or conditionally approved) to administer the CAHPS Hospice Survey. Registration for the upcoming training session is anticipated to open the end of August. Additional details related to the upcoming training will be posted on the CAHPS Hospice Survey Web site (www.hospicecahpssurvey.org) closer to the scheduled training date.
HOSPICES WERE ALSO REMINDED THAT HOSPICE COMPARE WILL LAUNCH SOME TIME DURING THE MONTH OF AUGUST. No additional information was available on the timing of the launch.
HOSPICE FY2018 PAYMENT RULE:
CMS representatives reminded attendees that the final FY2018 hospice payment rule was issued on August 1, 2017. A 1 percentage point update over FY2017 rates will be provided beginning October 1, 2017. A summary of the final rule developed by NAHC is available HERE.