During July the Centers for Medicare & Medicaid Services (CMS) issued a proposed regulation governing home health payment rates for calendar year (CY) 2013; included as part of that rule are comments from CMS about next steps relative to the Hospice Quality Reporting Program (HQRP). The National Association for Home Care & Hospice ’s and Hospice Association of America (HAA) submitted comments on these next steps. The final rule for home health payment rates for CY2013 and CMS’ next steps for the HQRP (beginning on page 66) was released Nov. 2, 2012.
In the proposed rule CMS indicated it does not intend to require the reporting of additional measures for the fiscal year (FY) 2015 payment year over those requirements already in place for the FY2014 payment year. HAA and most commenters were supportive of this step and the step to eliminate, in payment year 2015, the requirement that hospices provide a list of their patient care indicators for the structural measure. Based on these comments CMS finalized their plans as stated in the proposal. Following are two tables taken from the final rule as published by CMS (on page 70 of the document) that delineate current plans for the HQRP in the near term:
TABLE 26:Finalized in the CY 2013 HH PPS Final Rule
TABLE 27: Target Dates
CMS has undertaken development and testing of an initial hospice patient-level data item set with the goal of developing a quality reporting program that utilizes standardized methods to collect and submit data about patients admitted to hospice. While this process is still under way, CMS has indicated that a data set could be implemented as early as CY2014. In comments, HAA cautioned that as part of the development and testing process CMS must ensure that:
- Each of the data elements it proposes to collect is appropriate for hospice patients;
- Collection/reporting of data elements applicable to only a subset of a hospice’s patient population not be required on all patients; and
- Collection/reporting requirements be phased in if necessary to limit the burden on hospice programs
CMS received other comments similar to these as well as some indicating opposition to any type of standardized data set. CMS indicated it will make every effort to streamline the item set so that it contains only data elements appropriate for hospice patients and required to calculate quality measures for reporting, thereby minimizing burden. CMS acknowledged that it is important to include data elements that are appropriate for hospice patients and intend to include items that hospices already collect as part of their assessment and care delivery processes. The data items CMS is including in development of the data set and that it envisions being included in data collection in 2015 support the following National Quality Forum (NQF)-endorsed measures:
- 1617 Patients Treated with an Opioid who are Given a Bowel Regimen
- 1634 Pain Screening
- 1637 Pain Assessment
- 1638 Dyspnea Treatment
- 1639 Dyspnea Screening
CMS also indicated that they are considering utilization of a satisfaction of care survey and a measure that captures this, such as NQF measure 0208 Family Evaluation of Hospice Care (FEHC). HAA commented that the FEHC survey is a comprehensive and useful measure but its length could serve as a deterrent to grieving family members. Other commenters agreed and also suggested that mandatory use of the FEHC would only be supported if it were administered by a third party. CMS responded that they appreciate the feedback and will consider it as they move forward with HQRP.
HAA thanks member agencies that have shared comments, concerns, and suggestions with us so we can advocate for you and your patients. We are pleased that CMS has put forth such an extensive effort in obtaining input and feedback from providers as they expand the HQRP.
From the NAHC Report Article