Table of Content
We also proposed to increase the timeframe for submitting New Measures data from seven calendar days to fifteen calendar days following the end of each reporting period to account for weekends and holidays. The finalized set of applicable measures is presented in Table 24, which excludes the four measures we proposed to remove. For the reasons stated below and in consideration of the comments received, we are finalizing this measure set for PY1 and each subsequent performance year until such time that another set of applicable measures, or changes to this measure set, are proposed and finalized in future rulemaking. Since we are not adding or changing reporting requirements, providers should not have an increase in burden due to this policy.
We calculated the benchmarks and achievement thresholds for each OASIS measure for the smaller- and larger-volume cohorts and state-wide for each of the nine states using these data. However, the overall variation in these values was more than we expected, given the previous analyses. Visits performed solely for the purposes of furnishing NPWT using disposable device would not be reported on the HH PPS claim . Some commenters stated that the nominal case-mix reductions were duplicative of the rebasing reductions. A few commenters stated that the baseline used in calculating the amount of case-mix growth was inappropriate. Commenters stated that any analysis of case mix in home care must be put in the context of the current environment and take into account initiatives and trends.
for 101 CMR 350.00: Rates for Home Health Services
We note that the guidance as delineated in the guidance manual should be utilized to guide definitional interpretation and coding for these items that are used to calculate this proposed quality measure. However, guidance should not supersede the immediate actions needed by the HHA for appropriate clinical care. The World Health Organization regards medication reconciliation as a standard operating protocol necessary to reduce the potential for ADEs that cause harm to patients.
Lastly, we will update the payment rates by the CY 2017 HH payment update percentage of 2.5 percent as described in section III.C.1 of this final rule. With regards to the methodology used to calculate the cost of an episode of care in order to determine the payment amount under the HH PPS for high-cost “outliers” , in section III.D.2, we considered maintaining the current methodology used to calculate the cost of an episode of care (cost-per-visit). Since the projection of the percentage of outlier dollars is the same as before the change, the impact of this proposal is budget neutral. We propose to build upon the current confidential quality measure reports we already generate for HHAs so as to also provide data and information on the measures implemented in satisfaction of the IMPACT Act. As a result, HHAs could review their performance on these measures, as well as those already adopted in the HH QRP. We propose that these additional confidential feedback reports would be made available to each HHA through the CASPER System.
III. Provisions of the Proposed Rule and Analysis of and Responses to Comments
All the factors described require a social and financial adaptation with a strong impact on the quality of life of older adults and their caregivers. These changes can be adapted to strategies that translate into effective health gains, such as quality of life. While just about every provider in the home care space has struggled with turnover, lower wages are tied to higher turnover rates, a new report confirms. Table 39 provides the payment adjustment distribution based on proportion of dually-eligible beneficiaries, average case mix , proportion that reside in rural areas, as well as HHA organizational status. Besides the observation that higher proportion of dually-eligible beneficiaries serviced is related to better performance, the payment adjustment distribution is consistent with respect to these four categories. In addition, we finalized a proposal to continue this pattern for each subsequent year beyond CY 2014.
We believe this process adequately balances our need to incorporate updates to the HH QRP measures in the most expeditious manner possible while preserving the public's ability to comment on updates that do not fundamentally change a measure that it is no longer the same measure that we originally adopted. Commenters expressed concern that lack of risk-adjustment for these factors may compromise credibility, provide disincentives to serve certain patients and make it difficult to validly compare providers across PAC settings. A few commenters suggested that CMS could take advantage of the National Quality Forum's sociodemographic adjustment trial period.
E. Public Display of Total Performance Scores for the HHVBP Model
In addition, we have conducted an analysis and prototype testing of a java-based grouper with our Fiscal Intermediary Shared System maintenance contractor. Adopting such a process would improve payment accuracy by improving the accuracy of HIPPS codes on claims and decrease costs and burden to HHAs. Clinical practice guidelines for disposable NPWT devices recommend topical dressing changes at least one time per week in between those visits where a new disposable NPWT device is applied or replaced in its entirety. Therefore, if clinical practice guidelines are followed, there will be skilled nursing visits pertaining to wound management, other than for applying a disposable NPWT device in its entirety, and those services would be billed for on the HH PPS claim , when medically reasonable and necessary. It is measured by multiplying the number of minutes of services that occur during an episode by a wage rate for the disciplines providing the care. In conducting the recalculation, CMS will review the applicable measures and performance scores, the evidence and findings upon which the determination was based, and any additional documentary evidence submitted by the home health agency.
The payment adjustment percentages were calculated at the state and size level so that each HHA's payment adjustment was calculated as it will be in the Model. As noted, under the proposed procedure, during the 30-day preview period, HHAs would not be able to submit corrections to the underlying claims data or add new claims to the data extract. In the CY 2014 HH PPS final rule , we finalized a proposal to consider OASIS assessments submitted by HHAs to CMS in compliance with HH CoPs and Conditions for Payment for episodes beginning on or after July 1, 2012, and before July 1, 2013, as fulfilling one portion of the quality reporting requirement for CY 2014.
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The calculation of the proposed quality measure would be based on the data collection of three standardized items that would be added to the OASIS. The collection of data by means of the standardized items would be obtained at start or resumption of care and end of care. For more information about the data submission required for this proposed measure, we refer readers to Section I. Form, Manner, and Timing of OASIS Data Submission and OASIS Data for Annual Payment Update.
We will not be responsible for providing HHAs with the underlying source data utilized to generate performance measure scores because HHAs have access to this data via the QIES system. The following is a summary of the comments we received regarding our future plans to group HH PPS claims centrally during claims processing. ++ For furnishing NPWT using a disposable device, that is, the application of the new disposable NPWT device and the time spent instructing the beneficiary about ongoing wound care, the HHA would bill using a TOB 34x with CPT® code or 97608. In addition to the conventional NPWT systems classified as durable medical equipment , NPWT can also be performed using a disposable device. A disposable NPWT device is a single-use integrated system that consists of a non-manual vacuum pump, a receptacle for collecting exudate, and dressings for the purposes of wound therapy. These disposable systems consist of a small pump, which eliminates the need for a bulky canister.
Mix weights—adjusting the weights relative to one another—using the most current, complete data available. Conclude that the policies proposed in this rule would result in an estimated total impact of 3 to 5 percent or more on Medicare revenue for greater than 5 percent of HHAs. Therefore, the Secretary has determined that this HH PPS proposed rule would have a significant economic impact on a substantial number of small entities.
This age group presents distinct health, social, and economic needs that can be facilitated by the implementation of person-centered interventions. The institute of medicine defines person-centered care as being responsive to the preferences, values, and needs of the person, being respectful and responsive, and ensuring informed decision-making. It also states that this approach requires a true connection between the person and health professionals . The informal caregiver can be the family member of the person being cared for, who lives with the person and does not receive remuneration for the care provided .
MSPB-PAC HH QRP episodes, constructed according to the methodology described below, have high levels of Medicare spending with substantial variation. In FY 2014, Medicare FFS beneficiaries experienced 5,379,410 MSPB-PAC HH QRP episodes triggered by admission to a HHA. The mean payment-standardized, risk-adjusted episode spending for these episodes was $10,348 during that fiscal year.
Thus, HHAs have been required to collect OASIS data since 1999 and report HHCAHPS data since 2012. ++ For the Thursday visit, while the nursing services included wound assessment and application of a component of the disposable NPWT device, the nurse did not furnish a new disposable NPWT device. Therefore, the nurse did not furnish NPWT using a disposable device, so the HHA should report all the nursing services for the visit, including the catheter change and the wound care, on TOB 32x. The proportion of additional costs over the outlier threshold amount paid as outlier payments is referred to as the loss-sharing ratio, which is currently 0.80. We will continue to use the same methodology discussed in the CY 2007 HH PPS final rule to address those geographic areas in which there are no inpatient hospitals, and thus, no hospital wage data on which to base the calculation of the CY 2017 HH PPS wage index. For rural areas that do not have inpatient hospitals, we will use the average wage index from all contiguous CBSAs as a reasonable proxy.
Trade Adjustment Assistance
The outlier threshold for each case-mix group is the episode payment amount for that group, or the partial episode payment adjustment amount for the episode, plus a fixed-dollar loss amount that is the same for all case-mix groups. The beneficiaries in these clinical case mix categories have a greater degree of clinical similarity than the overall HHA patient population, and allow us to more accurately estimate Medicare spending. Given the comments received, we propose to include the Medicare spending for hospice services but risk adjust for them, such that MSPB-PAC HH QRP episodes with hospice are compared to a benchmark reflecting other MSPB-PAC HH QRP episodes with hospice. In the CY 2016 HH PPS final rule , we stated that one of the three goals of the HHVBP Model is to “Enhance current public reporting processes”. Annual publicly-available performance reports would be a means of developing greater transparency of Medicare data on quality and aligning the competitive forces within the market to deliver care based on value over volume.
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