Hospice will soon be experiencing a number of changes to quality assessment performance improvement (QAPI). These changes are driven by CMS’ commitment to increasing the availability and use of healthcare information for informed decision-making and quality improvement, coupled with a legislative mandate in the Affordable Care Act to begin implementation of a hospice quality reporting program. CMS’ FY2014 Proposed Rule identified a number of new measures and data sets beginning in 2015. If the proposed measures and timeline are finalized, it will be challenging for hospices to implement all of the new QAPI requirements. It’s not too early for hospices to begin preparing for these changes now.
What Can Hospices Expect?
Hospices should be currently collecting data for the QAPI Structural Measure and NQF 0209 measure for all of 2013. Data submission is April 1, 2014. After the FY2014 data collection year, CMS proposes that the QAPI structural measure and NQF#0209 that were required in FY2012/2013 be discontinued. The structural measure was used to ascertain the depth and breadth of existing QAPI programs and CMS determined that further reporting is not necessary. Due to difficulties implementing the NQF Pain Measure, CMS believes it is unsuitable for long term use in quality reporting. CMS may decide to keep NQF#0209 if an adequate pain outcome measure is not found to replace it.
Introduction of the Hospice Item Set (HIS) July 1, 2014. The Hospice Item Set contains 7 new measures. Similar to the Outcome and Assessment Information Set (OASIS) in home health care, electronic data submission is required on admission and discharge for every patient. Hospices who fail to report quality data will have a 2% market basket reduction for FY2016. Specifics of the reporting system and precisely when specific measures would be made available have not yet been determined. Public reporting of the HIS is not expected until 2018. Before public reporting can begin, the validity and reliability of data submitted beginning July 1, 2014 needs to be analyzed, which will take at least 4 quarters of data. Specifications of the proposed HIS measures are available via the Quality Forum. Examples of the HIS forms are available from CMS.
CMS also announced a new post-death family caregiver survey called the Hospice Experience of Care Survey that is also proposed to begin in 2015. Mandatory compliance with continuous monthly data reporting begins April 1, 2015 for FY2017 payment update. The survey, which draws heavily from the Family Evaluation of Hospice Care (FEHC) survey, is currently being field-tested. The FEHC was not used because it did not contain some of the questions that were identified as important by the public and it was not nationally standardized. Hospices with fewer than 50 deaths in 2014 are exempt, but they must submit their patient counts to qualify for the exemption. Some specifics regarding the Hospice Experience of Care Survey include:
- There are 3 versions determined by location of death: 1) home; 2) nursing home; and 3) inpatient care. Each version contains a set of core questions with additional setting-specific questions.
- It focuses on the patient/caregiver experience of care, rather than on patient satisfaction.
- The survey includes questions about provider communication and care plus patient and family characteristics
- Hospices must contract with a vendor for survey administration and quarterly data submission.
- More information can be found at Hospice CAHPs (Consumer Assessment of Healthcare Providers and Systems)
What Can Your Hospice Do Now?
- Begin testing the new HIS measures in your program. Monitor your results and conduct a Performance Improvement Project (PIP) if necessary.
- Participate in a performance improvement measurement system to obtain comparative data. Examples include NHPCO DART system (NHPCO members only), Quality Navigator from Deyta LLC, and QAPI Snapshot from OCS HomeCare.
- Familiarize your self with the additional resources listed below.
- Hospice Provider Toolkit
- CMS HelpDesk/CMS Hospice
- NHPCO Performance Measures including FEHC
- Federal Register Proposed Rule
- NHPCO Patient Outcomes and Measures (POM)
Posted by Terri Maxwell, PhD APRN, Vice President, Strategic Initiatives, Weatherbee Resources, Inc. & Hospice Education Network Inc.
Learn more about QAPI and other important compliance-related topics at Weatherbee's upcoming Hospice Regulatory Boot Camp.