Home health agencies typically assess and monitor patients’ functional status in order to create personalized care plans, ensure accurate reimbursements, and provide data for quality reporting.
Currently, agencies utilize OASIS items from Section G, the M1800s, to calculate reimbursement, star ratings, and Value-Based Purchasing (VBP) scores. However, effective January 1, 2025, Medicare will implement a significant shift, replacing the G items (M1800s) with GG items in the Quality Reporting Program (QRP) and VBP. In VBP, the Total Normalized Composite (TNC) scores for self-care and mobility will be replaced by the Discharge Function Score.
The GG items prove to be more efficient in identifying variations in function, with more specific guidance compared to what is currently used for the M1800s.
GG Item Scoring Challenges
- Improving the accuracy of scoring on the GG items has been challenging because some clinicians mistakenly think that the responses to GG items must align with those for the functional M1800 items. This misconception can lead to confusion and errors in documentation. Automated systems or scrubbers may flag perceived discrepancies. It’s essential for clinicians to fully understand the guidance for GG items to avoid these pitfalls and ensure accurate assessments. Notably, the completion guidance and scoring criteria vary considerably between G items and GG items.
- CMS has also reported that home health agencies have excessively used the response ‘activity not assessed’ (ANA) codes (07, 09, 10, 88, and the dash). Previously, CMS assigned these ANA codes to 01-dependent, but going forward, they will attribute them to a score based on patient characteristics reported elsewhere in the assessment. Relying on ANA codes inappropriately may lead to skewed results, which will likely have a negative impact on outcomes.
Staff education and quality improvement programs should stress the importance of following official CMS guidance and prioritizing accurate responses over the use of ANA responses. In the future, CMS will not only compare responses provided at the Start of Care (SOC) or Resumption of Care (ROC) to Discharge (DC) as they currently do, but will also compare the DC response to their imputed outcome for that patient.
By correctly employing GG items for their intended purpose, home health professionals can enhance the accuracy of their responses, precisely identify patients’ levels of function, actively work towards improving that function, and reflect genuine outcomes.
Further Guidance
The 2024 Final Rule states that the introduction of the new Discharge Function Score is slated for January 1, 2025, with the industry’s baseline year set as 2023. Therefore, home health agencies should utilize 2024 to enhance the accuracy of their responses to GG items, aiming to elevate their scores and achieve better outcomes data in comparison to other agencies in the same cohort.
Many recent changes in OASIS-E and the QRP programs result from the need for standardized data in post-acute care outlined in The Improving Medicare Post-Acute Care Transformation Act (IMPACT Act) of 2014. Utilizing the GG items for outcomes instead of the M1800s is likely the initial phase toward potentially removing the M1800 functional items from the OASIS in the future. By 2025, all post-acute settings shall use the GG items for QRP and VBP.
For example, last October 1, 2023, CMS replaced the Skilled Nursing Facility (SNF) legacy functional items with GG items, serving as the primary method for assessing and tracking patients’ functional status during their SNF stay.
Ultimately, the transition from G-section items to GG items in Medicare’s patient assessment framework represents a crucial step toward improved accuracy and standardization.
