Section 2(a) of the Improving Medicare Post-Acute Care Transformation Act of 2014 (the IMPACT Act) requires the public reporting of data on HHAs, Skilled Nursing Facilities (SNFs), Inpatient Rehabilitation Facilities (IRFs), and Long-Term Care Hospitals (LTCHs) quality measures and data on resource use and other measures for home health care billing. The Act also requires the Secretary to modify PAC assessment instruments to provide for the submission and comparison of standardized, and interoperable, patient assessment data on quality measures for home health billing. These requirements are intended to enable interoperability as well as improve quality and discharge planning, among other purposes.
Following opportunities for proposed rule public comment, as well as measure development related technical expert review and public comment and the review by the measures application partnership process, in this final rule and beginning with the CY 2018 payment determination, CMS adopted four measures to meet the requirements of the IMPACT Act. Three of these measures are calculated using Medicare claims. The Total Medicare Spending per Beneficiary - Post Acute Care Home Health Quality Reporting Program (MSPB-PAC HH QRP) measure does not require additional data submission. The fourth measure is assessment-based and is calculated using Outcome and Assessment Information Set (OASIS) data. The various measures are as follows:
- Potentially Preventable 30-Day Post-Discharge Readmission Measure for Post-Acute Care HH Quality Reporting Program;
- Total Medicare Spending per Beneficiary - Post Acute Care HH Quality Reporting Program (MSPB-PAC HH QRP);
- Discharge to Community- Post Acute Care HH Quality Reporting Program; and
- Drug Regimen Review Conducted with Follow-Up for Identified Issues-Post-Acute Care HH Quality Reporting Program.
The HH Conditions of Participations (CoPs) require HHAs to submit OASIS assessments for quality measurement purposes; submission of OASIS data is also required as a condition of payment. HHAs that do not submit quality measure data to CMS will see a 2.0 percent reduction in their annual payment update (APU). Last year CMS finalized its proposal to require all HHAs to submit both admission and discharge OASIS assessments for a minimum of 90 percent of all patients with episodes of care occurring during the reporting period. CMS is incrementally increasing this compliance threshold from 70 percent to 90 percent over a three-year period beginning with the reporting period for CY 2017 (July 1, 2015-June 30, 2016) for home care billing.
In 2015, CMS undertook a comprehensive reevaluation of all 81 HH quality measures, some of which are used only in the HH Quality Initiative (HHQI), and others which are also used in the HH QRP. The goal of this reevaluation was to streamline the measure set, consistent with Measures Management System (MMS) guidance and in response to stakeholder feedback for home health medicare billing. This reevaluation included a review of the current scientific basis for each measure, clinical relevance, usability for quality improvement, and evaluation of measure properties, including reportability and variability.
CMS’s measure development and maintenance contractor convened a Technical Expert Panel (TEP) on August 21, 2015, to review and advise on the reevaluation results. Information regarding the TEP’s feedback is available at: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/MMS/Downloads/Health-Quality-Reporting-Program-HHQRP-TEP-.zip. As a result of the comprehensive reevaluation, CMS identified 28 HHQI measures that were either “topped out” and/or determined to be of limited clinical and quality improvement value by TEP members. Therefore, these measures will no longer be included in the HHQI. A list of these measures, along with our reasons for no longer including them in the HHQI, can be found at the following link: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/HHQIQualityMeasures.html. Your home health billing software should account for these HHQI changes.
In addition, based on the results of the comprehensive reevaluation and the TEP input, we finalized to remove six process measures from the HH QRP, beginning with the CY 2018 payment determination, because they are “topped out” and therefore no longer have sufficient variability to distinguish between providers in public reporting.