WASHINGTON, D.C. (July 26, 2019)—In the 2020 home health prospective payment system (HHPPS) rate update proposed rule, the Centers for Medicare & Medicaid Services (CMS) proposes a number changes to the Home Health Quality Reporting Program (HHQRP) for calendar year (CY) 2022.

CMS proposes to eliminate one measure and add two new measures. In addition, in accord with the requirements of the Improving Medicare Post-Acute Care Transformation (IMPACT) Act, several new standardized patient assessment data elements (SPADEs) will be added to the Outcome and Assessment Information Set (OASIS) data set in CY 2021.

CMS proposes to remove the “Improvement in pain interfering with activity measure” from the HHQRP, citing concerns with unintended consequences related to the opioid crisis.

The two new measures proposed are:

  • Transfer of Health Information to the Provider-Post-Acute Care (PAC);
  • Transfer of Health Information to the Patient-Post-Acute Care (PAC).

The measures address whether the agency provided a subsequent provider with a medication list when the patient transfers to another health care provider and if the patient/caregiver was provided with a medication list when the patent is discharged to the community. The route of transmission of the medication list will also be captured with the transfer of information measures.

The new assessment items fall under the IMPACT Act domains of cognitive function; special services, treatments, and interventions; medical conditions and comorbidities; impairments; and social determinants of health. CMS originally proposed many of these assessment items in the 2018 HHPPS rate update rule but did not finalize the items due to concerns over the burden for agencies if implemented with the new GG functional items.

Under the cognitive domain CMS proposes three assessment screens for mental status, confusion/delirium, and mood. The special service, treatments and intervention assessment items asks the agency to select services and treatment the patient is receiving, along with identifying any high risk drugs the patient is taking. The assessment item for medical conditions and comorbidities addresses whether the patient has pain during several activities, and impairments are assessed through items for hearing and vision.

One new domain that CMS is proposing addresses social determinants of health and includes items for race, ethnicity, preferred language, interpreter services, health literacy, transportation, and social isolation.

With the proposed new measures and new assessment items, agencies will see a revised OASIS assessment for 2021 that is very different than the OASIS data set agencies currently collect.

The National Association of Home Care & Hospice (NAHC) sees two possible approaches in addressing the proposed changes to the HHQRP and is seeking input from providers.

  1. Recommend that CMS stagger the implementation of the assessment items over several HHQRP years. However, this would result in more iterations of the OASIS assessment tool, and changes to the assessment tool carries its own burdens and costs.
  2. Or, support the new assessment items with the condition that CMS issues a draft version of the revised OASIS data set no less than six months before the implementation date.

Although there are numerous new assessment items proposed, the assessment items are not very complex to complete and may not take as much training for clinicians as do more complex assessment items.

CMS should also consider applying the Paperwork Reduction Act (PRA) waiver authority provided by the IMPACT Act. The Secretary has the authority to not apply the PRA requirements when revisions to the post-acute care assessment tools are related to the requirements of the IMPACT Act. CMS will be able to skip several steps required by the PRA to expedite submission to the Office of Management and Budget for approval, and hence, may expedite a final version of the revised OASIS assessment tool.

To review the data specification document for the HHQRP measures and the SPADEs click here.

To view a proposed HHQRP items mock-up click here.

To view the change table for the proposed HHQRP items click here.

—Via NAHC, edited for style and clarity.