Public Reporting of Quality Data Looms – Are Providers Prepared?
Hospice Compliance Letter, March 2017
As the federal Centers for Medicare and Medicaid Services (CMS) continues its inexorable march toward the long-awaited Holy Grail of publicly reported, comparable quality data on hospices to be posted on its planned “Hospice Compare” website, some new intermediate requirements for data reporting go into effect April 1. CMS’ Hospice Quality Reporting Program (HQRP) is comprised of two principal elements, the Hospice Item Set (HIS) and the Consumer Assessment of Healthcare Providers and Systems (CAHPS) Hospice Survey. HQRP was created in 2010 to promote delivery of high-quality hospice services through required reporting of outcomes from hospice care. Hospices started reporting these data in 2014, and penalties are now up to 2 percent of their annual Medicare reimbursement update for failure to comply with reporting requirements.
The new HIS reporting requirements include seven elements for hospices to capture and report, three for every patient admitted starting April 1 and four for every patient discharged on or after April 1, including level of care and visits by discipline in final seven days of life. These HIS elements will be used to generate two new measures of quality: hospice visits when death is imminent, and hospice and palliative care composite process measure. The Hospice CAHPS 47-question, postdeath survey on experience of care is sent to the identified primary caregiver two months after the patient’s death by an authorized survey vendor with whom the hospice contracts. The eventual public posting of quality data at Hospice Compare, now projected to start in late summer 2017, will offer a decision guide for consumers, data to aid hospices in internal quality improvement efforts and benchmarking with other providers, and information for CMS to use in monitoring care provision, with future annual payment updates tied to how a hospice performs on the reported outcomes measures.
“There is now another process of data gathering and review required of the hospice at the time of discharge,” says Liz Silva, director of home health & hospice at HEALTHCAREfirst. “It can be challenging to accurately extract daily visits by discipline at the time of discharge. Hospices need to be aware of the regulatory deadlines and make sure data pulled by their electronic health record (EHR) vendor are correct. It sounds simple, but it’s not necessarily a straightforward process for every hospice—or every EHR,” she says. At press time, some EHR companies had still not released their updates for April 1. Hospices must include these new HIS items in the XML files they submit to CMS or the records will be rejected, possibly exposing the provider to penalties.