{"id":234,"date":"2018-05-16T07:00:18","date_gmt":"2018-05-16T07:00:18","guid":{"rendered":"https:\/\/advantagehcconsulting.com\/blog\/?p=234"},"modified":"2018-05-15T14:59:25","modified_gmt":"2018-05-15T14:59:25","slug":"quality-quality-takes-center-stage-in-proposed-hospice-rule","status":"publish","type":"post","link":"https:\/\/advantagehcconsulting.com\/blog\/2018\/05\/16\/quality-quality-takes-center-stage-in-proposed-hospice-rule\/","title":{"rendered":"Quality: Quality Takes Center Stage In Proposed Hospice Rule"},"content":{"rendered":"<p><img loading=\"lazy\" decoding=\"async\" class=\"aligncenter size-full wp-image-235\" src=\"https:\/\/advantagehcconsulting.com\/blog\/wp-content\/uploads\/2018\/05\/quality.jpg\" alt=\"\" width=\"620\" height=\"413\" srcset=\"https:\/\/advantagehcconsulting.com\/blog\/wp-content\/uploads\/2018\/05\/quality.jpg 620w, https:\/\/advantagehcconsulting.com\/blog\/wp-content\/uploads\/2018\/05\/quality-300x200.jpg 300w, https:\/\/advantagehcconsulting.com\/blog\/wp-content\/uploads\/2018\/05\/quality-210x140.jpg 210w\" sizes=\"auto, (max-width: 620px) 100vw, 620px\" \/><\/p>\n<p><strong><em><span style=\"color: #ffffff;\">Check out new time frames for Hospice Item Set data review.<\/span><\/em><\/strong><\/p>\n<p>You\u2019d better pay close attention to your Hospice Quality Reporting Program-related duties in 2019, because that\u2019s something the feds seem very focused on.<\/p>\n<p>The\u00a0<strong>Centers for Medicare &amp; Medicaid Services\u00a0<\/strong>is giving hospices a \u201cfairly easy\u201d payment update rule for fiscal year 2019, compared to some of the big regulatory and payment changes that have taken place in recent years, notes\u00a0<strong>Carrie Cooley\u00a0<\/strong>with\u00a0<strong>Weatherbee Resources\u00a0<\/strong>in Hyannis, Massachusetts.<\/p>\n<p>\u201cI was quite surprised there were not more impactful changes for hospice,\u201d Cooley says<\/p>\n<p>But despite getting a breather, hospices will need to focus on their HQRP duties and CMS appears to get more serious about them in the rule that was released April 27. CMS includes a number of Hospice Compare changes\u00a0as well as these quality-related provisions:<\/p>\n<ul>\n<li><strong><span style=\"color: #ffffff;\">Sub-Regulatory Process.<\/span>\u00a0<\/strong>CMS plans to move quality measure display over from official rulemaking to a \u201csub-regulatory\u201d process, it signals in the rule published in the May 8\u00a0<em>Federal Register<\/em>. CMS outlines a number of steps it takes in the process of deciding whether to publicly display a measure.<\/li>\n<\/ul>\n<p>\u201cBecause we follow the \u2026 outlined processes in determining the readiness for a quality measure to be publicly reported, and perform the necessary analysis to determine and demonstrate that our measures meet the [<strong>National Quality Forum<\/strong>] standards for reliability, validity, and reportability, prior to publicly reporting provider performance on these quality metrics, we are proposing to announce to providers, any future intent to publicly report a quality measure on Hospice Compare, including timing, through sub-regulatory means,\u201d the rule says.<\/p>\n<p>That will mean hospices will lose the official comment process that the annual payment rule now provides, notes\u00a0<strong>Judi Lund Person\u00a0<\/strong>with the\u00a0<strong>National Hospice &amp; Palliative Care Organization<\/strong>.<\/p>\n<ul>\n<li><strong><span style=\"color: #ffffff;\">HIS Review Time Frames.<\/span>\u00a0<\/strong>\u201cTo ensure that the data reported on Hospice Compare is accurate, we propose that hospices be provided a distinct period of time to review and correct the data that is to be publically reported,\u201d CMS says. \u201cThis approach would allow hospices a time frame in which they may analyze their data and make corrections &#8230; prior to receiving their preview reports. Once the preview reports are received, it is infeasible to make corrections to the data underlying the quality measure scores that are to be made public. Therefore, we are proposing that for data reported using the HIS that there be a specified time period for data review and a correlating data correction deadline for public reporting at which point the data is frozen for the associated quarter,\u201d according to the rule.<\/li>\n<\/ul>\n<p><strong><span style=\"color: #ffffff;\">The specifics:<\/span>\u00a0<\/strong>\u201cFor each calendar quarter of data submitted using the HIS, approximately 4.5 months after the end of each CY quarter we are proposing a deadline, or freeze date for the submissions of corrections to records,\u201d the rule says. \u201cWe note that this newly proposed data correction deadline for HIS records is separate and apart from the established 30-day data submission deadline.\u201d<\/p>\n<p>In other words, \u201ceach deadline would occur on the 15th of the CY month that is approximately 4.5 months after the end of each CY quarter, and that hospices would have up until 11:59:59 pm PST on that date to submit corrections or requests for inactivation of their data for the quarter involved. For example, for data reported in CY Q1, the freeze date would be August 15th, for CY Q2 the freeze date would be November 15th and so on,\u201d CMS explains.<\/p>\n<p>\u201cUnder this policy, any modification to or inactivation of records that occur after the proposed correction deadline would not be reflected in publicly reported data on the CMS Hospice Compare Web site.\u201d The new process would start Jan. 1.<\/p>\n<ul>\n<li><strong><span style=\"color: #ffffff;\">Consideration Factors.<\/span>\u00a0<\/strong>As part of CMS\u2019s Meaningful Measures initiative, the agency proposes to \u201cadopt an eighth factor to consider when evaluating measures for removal from the HQRP measure set: The costs associated with a measure outweigh the benefits of its continued use in the program.<\/li>\n<\/ul>\n<p>CMS believes costs can be multi-faceted and include not only the burden associated with reporting, but also the costs associated with complying with the program,\u201d according to a CMS fact sheet about the rule.<\/p>\n<p>\u201cThe rule proposes to remove measures based on this factor on a case-by-case basis,\u201d CMS adds in the fact sheet. \u201cFor example, a measure that is costly and burdensome might be retained for health care providers to report if CMS concludes that the value to beneficiaries is so high that it justifies the reporting burden. The goal is to move the program forward in the least burdensome manner possible, while maintaining a parsimonious set of meaningful quality measures and continuing to incentivize improvement in the quality of care provided to patients.\u201d<\/p>\n<ul>\n<li><strong><span style=\"color: #ffffff;\">CAHPS Exemptions.<\/span>\u00a0<\/strong>CMS proposes to continue volume-based and \u201cnewness\u201d exemptions on an ongoing basis. Exemptions for size requests still will have to be requested and approved annually.<\/li>\n<li><strong><span style=\"color: #ffffff;\">Social Risk Factors.<\/span>\u00a0<\/strong>CMS recaps its work on factors for risk adjustment that it terms \u201csocial\u201d \u2014 most notably dual-eligible status \u2014 in the rule. It includes a summary of comments received about the topic in last year\u2019s hospice payment rule, and notes that \u201cfeedback we received across our quality reporting programs included encouraging CMS to explore whether factors that could be used to stratify or risk adjust the measures (beyond dual eligibility); considering the full range of differences in patient backgrounds that might affect outcomes; exploring risk adjustment approaches; and offering careful consideration of what type of information display would be most useful to the public.\u201d CMS is still working on the issue, it pledges.<\/li>\n<\/ul>\n<p><span style=\"color: #ffffff;\"><strong>Toe in the water:\u00a0<\/strong><\/span>CMS is considering the use of social risk factors in the risk adjustment formula for new hospice measures under consideration, Lund Person says.<\/p>\n<p><em>Note: See the CMS fact sheet about the rule at\u00a0<a href=\"http:\/\/www.cms.gov\/Newsroom\/MediaReleaseDatabase\/Fact-sheets\/2018-Fact-sheets-items\/2018-04-27-3.html\">www.cms.gov\/Newsroom\/MediaReleaseDatabase\/Fact-sheets\/2018-Fact-sheets-items\/2018-04-27-3.html<\/a>.<\/em><\/p>\n<p><a href=\"https:\/\/www.supercoder.com\/coding-newsletters\/my-homecare-week-alert\/quality-quality-takes-center-stage-in-proposed-hospice-rule-157607-article\"><i><span style=\"font-weight: 400;\">Source- SuperCoder<\/span><\/i><\/a><\/p>\n","protected":false},"excerpt":{"rendered":"<p>Check out new time frames for Hospice Item Set data review. You\u2019d better pay close attention to your Hospice Quality Reporting Program-related duties in 2019, because that\u2019s something the feds &hellip; <a class=\"readmore\" href=\"https:\/\/advantagehcconsulting.com\/blog\/2018\/05\/16\/quality-quality-takes-center-stage-in-proposed-hospice-rule\/\">Continue Reading &rarr;<\/a><\/p>\n","protected":false},"author":1,"featured_media":235,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[8,16],"tags":[11,12,13,14],"class_list":["post-234","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-compliance","category-hospice","tag-home-care","tag-hospice","tag-ltc","tag-snf"],"_links":{"self":[{"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/posts\/234","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/comments?post=234"}],"version-history":[{"count":2,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/posts\/234\/revisions"}],"predecessor-version":[{"id":237,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/posts\/234\/revisions\/237"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/media\/235"}],"wp:attachment":[{"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/media?parent=234"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/categories?post=234"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/tags?post=234"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}