The Centers for Medicare & Medicaid Services (CMS) recently updated the Home Health Quality Reporting Program (HH QRP) Measure Calculations and Reporting User’s Manual. This is the first update since the Version 1.0 Addendum in October 2020 and it includes important additions, deletions, language corrections, and clarifications.
The User Guide updates primarily consisted of basic changes such as terminology updates, the addition of missing words, updated reference names, and definition clarifications.
The removal of some Quality Measures is included in these updates:
- Depression Assessment Conducted
- Multifactor Fall Risk Assessment Conducted for all Patients who can Ambulate
- Diabetic Foot Care
- Pneumococcal Vaccine Received
- Improvement in Status of Surgical Wounds
The updates also include the following additions:
- Home Health Within-Stay Potentially Preventable Hospitalization (PPH, PPOBS) – Claims-Based Measure
- Transfer of Health Information to the Patient – OASIS-Based Measure
- Transfer of Health Information to the Provider – OASIS-Based Measure
Quality Reporting Exclusion for Patients Discharged to Hospice
The HH QRP User Guide V.2.0 has an exciting addition that stakeholders have long requested. It is the denominator exclusion added to OASIS Outcome-Based QMs, which excludes patients discharged to a non-institutional hospice.
Effective 1/1/2023, OASIS-based quality measures for HH QRP will exclude episodes of patients discharged to non-institutional hospice care (as coded in M2420 Discharge Disposition, Response 3). This includes the following measures:
- Improvement in Dyspnea
- Improvement in Management of Oral Medications
- Improvement in Bathing
- Improvement in Bed Transferring
- Improvement in Ambulation/Locomotion
These updates fulfill a long-standing request from stakeholders to exclude hospice patients from HH QRP, which many agencies are happy about. Previously, agencies felt penalized for accepting patients requiring palliative care who were not yet physically or emotionally ready for hospice. CMS continuing to include these patients in the outcomes and star ratings disincentivized agencies from accepting them.
Impact on HHVBP and iQIES
The HH QRP update led to many questions about how it would affect the Home Health Value-Based Purchasing (HH VBP) items. In February 2023, CMS provided clarity with the Expanded HH VBP FAQs and new Outcome Measures Tables on the HH QRP site.
The HH VBP FAQs clarified that as of 1/1/2023, patients discharged to a non-institutional hospice (M0100 Reason for assessment – RFA 9 Discharge from Agency) where M2420 Discharge Disposition is coded with Response 3 – Patient transferred to a non-institutional hospice, and with an M0906 Discharge/Transfer/Death Date of 1/1/2023 or later, are excluded from the calculation of the following OASIS-based quality measures in the expanded HHVBP Model:
- Discharged to Community
- Improvement in Dyspnea
- Improvement in Management of Oral Medications
- Total Normalized Composite (TNC) Change Mobility
- Total Normalized Composite (TNC) Change in Self-Care
In addition, in the HHVBP Model (Q3020), episodes where the patient is transferred to an institutional hospice and where M2410 (Which Inpatient Facility has the patient been Admitted) is marked as response 4 Hospice, as well as episodes where the location is unknown (Q3022), are excluded for Discharge to the Community.
Starting from April 2023, agencies will see the positive effect of these updates in the iQIES reports, while the effect of the exclusions on Care Compare, which began on January 1, 2023, will not be seen until January 2024.
You can download all the new updates to the HH QRP program on the CMS Home Health QRP website and the Expanded HH VBP site. These include the following:
- HH QRP User Guide V.2.0 and change table
- Updated CY2023 Specifications for Risk Adjustment
- Changes in Skin Integrity and Potentially Preventable Hospitalizations
- Revised Home Health Outcome Measures, Process Measures, and Potentially Avoidable Event Tables
- Updated Expanded HH VBP FAQs
Pursuing Growth Opportunities
As demonstrated by the recent updates to the HH QRP User Guide, the changes in the industry regulations may indeed pose challenges, but they may also bring about opportunities. With support solutions and the right partner by their side, home health agencies can easily navigate these changes and be more agile in pursuing goals for business growth.
With the increasing demand of documentation work that comes along with growth in census, having a reliable partner to cover those tasks can alleviate the burden and allow agencies to focus on the things that matter most.