Hospices have a lot to juggle in 2018, including increased audit scrutiny and payment changes. But it’s the significant changes to hospice quality reporting that will have you scrambling to stay in compliance and avoid a payment penalty for failing to report your data.
Embedded in the payment update and changes for fiscal year (FY) 2018, the Centers for Medicare & Medicaid Services (CMS) has made important revisions to the Hospice Quality Reporting Program (HQRP), according to registered nurse Beth Noyce in her training session Hospice Updates for 2018: Final Rule, Payment Updates, and OIG Audits. Now more than ever before, you need to anticipate and prepare for these revisions to your quality reporting.
Enjoy More Time for Extension/Exception Requests
In the FY 2014 hospice final rule, CMS finalized the Hospice Item Set (HIS) as the data collection mechanism for reporting HQRP measures, according to a recent report by Health Policy Alternatives, Inc. (HPA). Beginning on or after Jan. 1, 2018 to Dec. 31, 2018, hospices must submit at least 90 percent for all HIS records within the 30-day submission timeframe or else face a 2-percentage point reduction in their FY 2020 market basket update.
Good news: But now, for the FY 2019 payment determination and going forward, CMS will extend the time period for your hospice to submit a request for an extension or exception from 30 calendar days to 90 calendar days after the date that an extraordinary circumstance occurred, according to a summary by Washington, DC-based Leading Age.
This provision will allow you extra time to focus on patient care during a situation like an unforeseen environmental emergency. The allowance will also align the HQRP requirements with the other post-acute care quality reporting programs.
Prepare for 8 New Quality Measures
What’s more: The hospice rule finalized eight quality measures from the Consumer Assessment of Healthcare Providers and Systems (CAHPS) Hospice Survey data, which you already submit, Leading Age stated. The CAHPS Hospice Survey data is now publicly available on Hospice Compare.
According to HPA, the eight finalized CAHPS Hospice Survey measures include:
- Rating of Hospice (MUC 16-31);
- Hospice Team Communications (MUC 16-32);
- Willingness to Recommend (MUC 16-33);
- Getting Hospice Care Training (MUC 16-35);
- Getting Timely Care (MUC 16-36);
- Getting Emotional and Religious Support (MUC 16-37);
- Getting Help for Symptoms (MUC 16-39); and
- Treating Family Member with Respect (MUC 16-40).
For FY 2018 and FY 2019 Annual Payment Update (APU) determinations, CMS now requires hospice facilities to contract with a CMS-approved vendor to collect CAHPS Hospice Survey data for eligible patients on a monthly basis, HPA explained. The vendor must report this data on your hospice’s behalf by the quarterly deadlines.
Hidden trap: But the fact that the vendor will report your data doesn’t mean you’re off the hook. CMS warns that if your vendor fails to submit data on time, it’s your hospice’s responsibility. The quarterly data submission deadlines are as follows:
- 8, 2018 – January through March 2018 (Q1);
- 14, 2018 – April through June 2018 (Q2);
- 13, 2019 – July through September 2018 (Q3); and
- May 8, 2019 – October through December 2018 (Q4).
Keep Your Eyes Peeled for Future Measures
Look ahead: In the hospice final rule, CMS also discussed two quality measures that are under development, HPA stated. “Potential Avoidable Hospice Care Transitions” would be a claims-based measure that would focus on transitions of care.
The second measure, “Access to Levels of Hospice Care,” would access the rates at which hospices provide different levels of hospice care according to the four levels of care under the Medicare Hospice Benefit: routine home care (RHC), continuous home care (CHC), general inpatient care (GIP), and inpatient respite care (IRC).
Bottom line: You’ll need to keep abreast of and understand the new and future hospice quality measures that will become part of the HQRP, Noyce stresses. If you don’t comply with these measures, you will face a 2-percentage-point reduction to your payments.