Quality reporting programs for home health and hospice: The what, when, why, and how
Regulatory requirements are changing constantly and remain top of mind for providers in terms of challenges. We have dedicated our careers to working with government affairs, the Center for Medicare and Medicaid Services (CMS), and other state and national regulatory bodies in order to understand the changes in regulations—not only from an innovation perspective but to educate providers and clients as well. Here, we’ll discuss the what, when, why, and how of quality reporting programs for home health and hospice so you can lead your organization with expert tips and knowledge on managing compliance, avoiding penalties, and achieving quality outcomes.
The what: What significance do quality reporting programs have on providers?
Quality reporting programs (QRPs) for home health and hospice are Medicare pay-for-performance programs, which means compliance is determined by the act of submitting timely and complete data. Noncompliance with the quality reporting program collection and submission requirements in a particular performance year can be costly to providers, as it results in a 2% payment penalty in the corresponding annual payment update year.
QRPs use the data collected to capture and calculate performance and quality measure data from agency-submitted claims, assessment/collection instruments (OASIS for home health, HIS for Hospice), and CAHPS survey instruments. Although the performance of those measures is not used in determining an agency’s compliance for pay for performance, the significance is that the performance and outcomes-based quality measure data and ratings are publicly reported on Care Compare, which is used as a source for comparing providers and making informed decisions by patients, caregivers, and other consumers, such as value-based payer entities.
The when: When can quality reporting programs affect your bottom line?
It’s in the agency’s best interest to ensure the data submitted not only meets compliance for avoiding a payment penalty but also meets agency quality and performance objectives for achieving best measure scores on Care Compare, which provides quality data to consumers and can impact referrals and the ability to win value-based contracting or partnership opportunities.
The right technology vendor is always one step (or several steps) ahead of these regulatory requirements, implementing workflow updates that keep your compliance on track without skipping a beat. Choosing a reliable CAHPS vendor is also vital to ensuring timely quarterly submission.
The how: How can quality reporting programs drive better outcomes?
Quality reporting programs should drive better processes, and the right technology integrates these processes directly into workflows. Specifically, your EHR system should support timely and accurate submissions on a proactive—versus reactive—basis. These solutions should promote coding and assessment accuracy and an effective quality review process. For example, an OASIS scrubbing tool helps improve OASIS accuracy and develop clinicians’ assessment skills.
If you outsource coding, an EHR platform that integrates those services with the quality review workflow is invaluable. On the hospice side, having EHR solutions that extract hospice item set (HIS) data directly from the hospice assessment and patient medical record will help maintain the utmost accuracy in the data and drive performance outcomes.
Your EHR should also have a strong analytics ability and support real-time data reporting for continuous quality improvement. Simply put, the right EHR vendor knows how to implement processes that take advantage of quality reporting programs to drive better outcomes.
The why: Why should you consider the future of quality reporting programs?
With the COVID-19 public health emergency still in effect, there are many unknowns as to what QRP changes CMS will propose in annual home health and hospice rule-making this year and next. Here are some potential quality reporting program, measure, and instrument changes we may see evolve quickly over the next year or two, and that home health and hospice agencies should be continually monitoring and preparing for:
- Ongoing development and implementation of standardized patient assessment data elements (SPADES) in post-acute care
- Interim OASIS revisions and updates on the delayed OASIS-E implementation
- Updates on the implementation of the new Hospice HOPE assessment (will replace HIS in the near future)
- COVID-19 vaccination collection and reporting measures
- Continued movement by CMS toward more claims-based measures
- Increased payment penalty for Hospice QRP noncompliance from 2 to 4% in FY 2024 (Consolidated Appropriations Act of 2021)
While there are always unknowns in this industry, it’s important to both stay educated on QRP requirements and participate in engagement opportunities with CMS to provide feedback and comments. Staying engaged and up to date on developments is crucial to better prepare your agency for 2021 and beyond.