New QAO Quality Reporting Requirement for Home Health

Start Date Begins This Week.

The Centers for Medicare and Medicaid Services (CMS) instituted payment related quality reporting requirements for home health agencies in regulation 42 CFR 484.250(a) several years ago. Since that time, agencies that have failed to report OASIS data and comply with Home Health Care Consumer Assessment of Healthcare Providers and Systems Survey (HHCAHPS) requirements have been subject to 2% reduction in their annual market basket update.

However, CMS never identified a required quantity for the OASIS reporting at that time. So (although noncompliant with the Conditions of Participation) home health agencies that submit just one OASIS Start of Care (SOC) followed by either a Transfer or End of Care (EOC) assessment for a single patient are deemed compliant with OASIS quality reporting requirements for payment purposes.

CMS was brought to task by the Office of Inspector General (OIG) in a 2012 report for failing to establish a minimum threshold for submission of OASIS data. The OIG wrote that “CMS did not ensure the accuracy or completeness of OASIS data” and advised CMS to “identify all HHAs that failed to submit OASIS data and apply the 2-percent payment reduction to them.” In response, CMS undertook work to develop a measurable performance requirement. The result of this work was announced in the 2015 PPS rule, with plans to initiate a new “Pay for Reporting Requirement” using its “Quality Assessment Only” (QAO) measure.

New QAO Quality Reporting Requirement

The new Pay for Reporting design that will “hold home health agencies accountable for reporting OASIS data” will begin in 2015 with all episodes of care starting on or after July 1 and ending June 30, 2016. During each payment update period, CMS will collect and calculate the number of Quality Assessments Only (QAO) that a home health agency submits. Quality Assessments are defined as two matching assessments for each patient that create a quality episode of care that can be used for quality measurement, compared with the total number that should be usable.

Home health agencies that do not attain a reporting score of 70% or more quality episodes collected from starting July 1, 2015 and before July 1, 2016 will be subject to a 2% reduction in the market basket update for CY 2017. And this is just the beginning, CMS plans to continue home health QAO data collection annually, with its ultimate goal for agencies to score 90% or greater in order to be considered compliant.

The seven OASIS assessments that fit the definition of Quality Assessments are:

  • A Start of Care (SOC) or Resumption of Care (ROC) assessment that has a matching End of Care (EOC) assessment.  EOC assessments are assessments that are conducted at transfer to an inpatient facility (with or without discharge), death, or discharge from home health care.
  • An SOC/ROC assessment that could begin an episode of care, but occurs in the last 60 days of the performance period.
  • An EOC assessment that could end an episode of care that began in the previous reporting period, (that is, an EOC that occurs in the first 60 days of the performance period.)
  • An SOC/ROC assessment that is followed by one or more follow-up assessments, the last of which occurs in the last 60 days of the performance period.
  • An EOC assessment is preceded by one or more Follow-up assessments, the last of which occurs in the first 60 days of the performance period.
  • An SOC/ROC assessment that is part of a known one-visit episode.

SOC, ROC, and EOC assessments that do not meet any of these definitions are labeled as “Non-Quality” assessments.

Follow-up assessments (that is, where the M0100 Reason for Assessment = ‘04’ or ‘05’) are considered “Neutral” assessments and do not count toward or against the pay for reporting performance requirement.

The formula CMS plan to use to calculate compliance is the “Quality Assessments Only” (QAO) formula as follows:

Quality Reporting Requirement Formula

What should home health agencies do now

  • Visit the CMS quality reporting site for full details and background here.
  • Review the Sample QAO report in the downloads section
  • Access and review your agency’s 2013-2014 QAO Historical Performance Report when it becomes available in your CASPER folder in late June 2015 (note this report is informational only and will not be used to reduce payment).
    • If your score is less than 70%, examine your OASIS assessment submission practices to determine whether the problem lies in failure to complete all required OASIS assessments (i.e., both those for SOC/ROC and for all EOC events), or failure to successfully submit all required OASIS assessments (i.e., both those for SOC/ROC and for all EOC events) or both.
    • Educate you staff about the importance to complete and submit all required OASIS assessments at the time points required by the CoP.

About Mary St. Pierre
After retiring from the National Association for Home Care & Hospice (NAHC) in 2013, Mary St. Pierre served as a national home health and hospice consultant. At this time she is engaged in an exclusive consulting agreement with HEALTHCAREfirst, providing regulatory guidance in the design and maintenance of software and data analytics. While with NAHC, Ms. St. Pierre oversaw the operations of the Regulatory Affairs Department, tracking regulations and influencing regulatory bodies such as CMS, FDA, and OSHA.  In addition, she prepared educational programs, presented speeches and programs and kept the membership abreast of regulatory and clinical information through articles in NAHC publications.  Ms. St. Pierre had 26 years experience as a home care nurse, clinical supervisor and manager within a large metropolitan home health agency prior to joining NAHC in 1993.

June 29, 2015

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