Table of Content
The proposed revised set of applicable measures is presented in Table 31, which excludes the four measures we propose to be removed. We propose that this measure set will be applicable to PY1 and each subsequent performance year until such time that another set of applicable measures, or changes to this measure set, are proposed and finalized in future rulemaking. Moving forward, we plan to utilize an implementation contractor who will invite a group of measure experts to provide advice on the adjustment of the current measure set. We are proposing to remove these four measures, for the reasons discussed below, beginning with the CY 2016 Performance Year calculations, and believe this will not cause substantial change in the first annual payment adjustment that will occur in CY 2018, as each measure is equally weighted and will not be represented in the calculations. The proposed revisions to the measure set, as set forth in Table 31 would be applicable to each performance year subject to any changes made through future rulemaking. In the CY 2011 HH PPS proposed rule we solicited comments on potential plans to group HH PPS claims centrally during claims processing and received many comments in support of this initiative.
We did not propose a change to the loss-sharing ratio (0.80) as a loss-sharing ratio of 0.80 for the HH PPS would remain consistent with payment for high-cost outliers in other Medicare payment systems (for example, IRF PPS, IPPS, etc.). In the CY 2017 HH PPS proposed rule, we stated that under the current outlier methodology, the FDL ratio would need to be increased from 0.45 to 0.48 to pay up to, but no more than, 2.5 percent of total payments as outlier payments. Therefore, in addition to the proposal to change the methodology used to calculate outlier payments, we proposed to increase the FDL ratio from 0.45 to 0.56 for CY 2017.
for 101 CMR 350.00: Rates for Home Health Services
In addition to assessment-based measures, we have also proposed claims-based measures for the HH QRP. As noted previously, section 1899B of the Act requires prepublication provider review and correction procedures that are consistent with those followed in the Hospital IQR program. Under the Hospital IQR Program's procedures, for claims-based measures, we give hospitals 30 days to preview their claims-based measures and data in a preview report containing aggregate hospital-level data. If this proposed measure is finalized, we intend to provide initial confidential feedback to home health agencies, prior to the public reporting of this measure, based on Medicare FFS claims data from discharges in CYs 2015 and 2016.
Has had a face-to-face encounter related to the primary reason for home health care with a physician or allowed Non-Physician Practitioner within a required timeframe. Given this prior rapid growth, and the reasons for the decline in home health use since 2010, MedPAC believes that the decline in utilization since 2010 does not raise substantive concerns about beneficiaries' access to home health care. We continue to believe that using the pre-floor, pre-reclassified hospital wage index as the wage adjustment to the labor portion of the HH PPS rates is appropriate and reasonable. The following is a summary of the comments we received regarding the CY 2017 home health rate update. Of this final rule, we have conducted research and analyses to potentially revise the HH PPS case-mix methodology.
III. Provisions of the Proposed Rule and Analysis of and Responses to Comments
All the factors described require a social and financial adaptation with a strong impact on the quality of life of older adults and their caregivers. These changes can be adapted to strategies that translate into effective health gains, such as quality of life. While just about every provider in the home care space has struggled with turnover, lower wages are tied to higher turnover rates, a new report confirms. Table 39 provides the payment adjustment distribution based on proportion of dually-eligible beneficiaries, average case mix , proportion that reside in rural areas, as well as HHA organizational status. Besides the observation that higher proportion of dually-eligible beneficiaries serviced is related to better performance, the payment adjustment distribution is consistent with respect to these four categories. In addition, we finalized a proposal to continue this pattern for each subsequent year beyond CY 2014.
This prototype edition of the daily Federal Register on FederalRegister.gov will remain an unofficial informational resource until the Administrative Committee of the Federal Register issues a regulation granting it official legal status. For complete information about, and access to, our official publications and services, go to About the Federal Register on NARA's archives.gov. And M.J.L.; resources, V.N., L.G.P. and C.F.; writing—original draft preparation, V.N.; writing—review and editing, L.G.P.; supervision, C.F., L.G.P. and M.J.L.; project administration, M.J.L.; funding acquisition, M.J.L. All authors have read and agreed to the published version of the manuscript. With this review, we intend to contribute to practice based on scientific evidence, with the future objective of further investigations contributing to this result. Multimorbidity and the loss of functioning result in the aging process that may require care provided by others in-home context.
E. Public Display of Total Performance Scores for the HHVBP Model
In addition, we have conducted an analysis and prototype testing of a java-based grouper with our Fiscal Intermediary Shared System maintenance contractor. Adopting such a process would improve payment accuracy by improving the accuracy of HIPPS codes on claims and decrease costs and burden to HHAs. Clinical practice guidelines for disposable NPWT devices recommend topical dressing changes at least one time per week in between those visits where a new disposable NPWT device is applied or replaced in its entirety. Therefore, if clinical practice guidelines are followed, there will be skilled nursing visits pertaining to wound management, other than for applying a disposable NPWT device in its entirety, and those services would be billed for on the HH PPS claim , when medically reasonable and necessary. It is measured by multiplying the number of minutes of services that occur during an episode by a wage rate for the disciplines providing the care. In conducting the recalculation, CMS will review the applicable measures and performance scores, the evidence and findings upon which the determination was based, and any additional documentary evidence submitted by the home health agency.
We also performed a similar analysis with the achievement thresholds and comparing how the individual benchmarks and achievement thresholds would fluctuate from one year to the next for the smaller-volume cohorts, larger-volume cohorts, and the state level cohorts. Since CY 2008, the HH PPS Grouper became more complex and more sensitive to annual diagnosis coding changes. As a result, in recent years, HHAs have been required to update their grouper software twice a year. HHAs have expressed concerns to us that the bi-annual grouper updates coupled with the additional complexity of the grouper has increased provider and vendor burden.
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Once they are available, we will take a gradual and systematic approach in evaluating how they might be incorporated. Medicare payments for Part A and Part B claims for services included in MSPB-PAC HH QRP episodes, defined according to the methodology previously discussed are used to calculate the MSPB-PAC HH QRP measure. The measure calculation is performed separately for MSPB-PAC HH Standard, PEP, and LUPA QRP episodes to ensure that they are compared only to other MSPB-PAC HH Standard, PEP, and LUPA episodes, respectively. The final MSPB-PAC HH QRP measure is the episode-weighted average of the average scores for each type of episode, as described below.
We will not be responsible for providing HHAs with the underlying source data utilized to generate performance measure scores because HHAs have access to this data via the QIES system. The following is a summary of the comments we received regarding our future plans to group HH PPS claims centrally during claims processing. ++ For furnishing NPWT using a disposable device, that is, the application of the new disposable NPWT device and the time spent instructing the beneficiary about ongoing wound care, the HHA would bill using a TOB 34x with CPT® code or 97608. In addition to the conventional NPWT systems classified as durable medical equipment , NPWT can also be performed using a disposable device. A disposable NPWT device is a single-use integrated system that consists of a non-manual vacuum pump, a receptacle for collecting exudate, and dressings for the purposes of wound therapy. These disposable systems consist of a small pump, which eliminates the need for a bulky canister.
Given the high costs of care in institutional settings, encouraging post-acute providers to prepare patients for discharge to community, when clinically appropriate, may have cost-saving implications for the Medicare program. In addition, providers have discovered that successful discharge to the community was a major driver of their ability to achieve savings, where capitated payments for post-acute care were in place. For patients who require long-term care due to persistent disability, discharge to community could result in lower long-term care costs for Medicaid and for patients' out-of-pocket expenditures. We proposed that an MSPB-PAC HH QRP episode would begin at the episode trigger, which is defined as the first day of a patient's home health claim with a HHA.
This age group presents distinct health, social, and economic needs that can be facilitated by the implementation of person-centered interventions. The institute of medicine defines person-centered care as being responsive to the preferences, values, and needs of the person, being respectful and responsive, and ensuring informed decision-making. It also states that this approach requires a true connection between the person and health professionals . The informal caregiver can be the family member of the person being cared for, who lives with the person and does not receive remuneration for the care provided .
Therefore, we believe the existing payment policy approach for LUPA episodes represents appropriate payment for episodes that include the furnishing of NPWT using a disposable device as the LUPA payment, and any eligible LUPA add-on, take into account the administrative costs. In addition, section 3131 of the Affordable Care Act mandates that rebasing must be phased-in over a 4-year period in equal increments, not to exceed 3.5 percent of the amount as of the date of enactment under section 1895 of the Act, and be fully implemented in CY 2017. Therefore, in the CY 2014 HH PPS final rule , we finalized rebasing adjustments to the national, standardized 60-day episode payment amount, the national per-visit rates and the NRS conversion factor. As we noted in the CY 2014 HH PPS final rule, because section 3131 of the Affordable Care Act requires a four year phase-in of rebasing, in equal increments, to start in CY 2014 and be fully implemented in CY 2017, we do not have the discretion to delay, change, or eliminate the rebasing adjustments once we have determined that rebasing is necessary . Next, as discussed in the CY 2016 HH PPS final rule , we would apply a reduction of 0.97 percent to the national, standardized 60-day episode payment rate in CY 2017 to account for nominal case-mix growth between CY 2012 and CY 2014. Then, we would apply the −$80.95 rebasing adjustment finalized in the CY 2014 HH PPS final rule , and discussed in section II.C.
The coefficients from the regression show how much more or less, on average, an episode's resource use is depending on responses to these items which is then used to predict resource use for each individual episodes. Ranking the episodes by predicted resource use and then identifying thresholds that divides episodes into three groups of roughly the same size allows us to assign each episode to into a low, medium or high functional/cognitive level. In total there would be 324 possible payment groupings an episode can be grouped into under the HHGM. Unlike the current payment model, the HHGM does not rely on the number of therapy visits performed to influence payment. In order to address those geographic areas in which there are no inpatient hospitals, and thus, no hospital wage data on which to base the calculation of the CY 2017 HH PPS wage index, we propose to continue to use the same methodology discussed in the CY 2007 HH PPS final rule to address those geographic areas in which there are no inpatient hospitals.
Trade Adjustment Assistance
There is strong evidence that medication discrepancies can occur during transfers from acute care facilities to post-acute care facilities. Discrepancies can occur when there is conflicting information documented in the medical records. Potential medication problems upon admission to HHAs have been reported as occurring at a rate of 39 percent of reviewed charts and mean medication discrepancies between 2.0 ± 2.3 and 2.1 ± 2.4. Similarly, medication discrepancies were noted as patients transitioned from the hospital to home health settings. An estimated fifty percent of patients experienced a clinically important medication error after hospital discharge in an analysis of two tertiary care academic hospitals. Following completion of that development work, we were able to test for measure validity and reliability as identified in the measure specifications document provided above.
