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Reporting Home Health Quality Data for Annual Payment Update

Overview

In 2005, the Deficit Reduction Act (DRA) Section 5201(c) (2) was passed by Congress and added section 1895(b) (3) (ii) (V) to the Social Security Act requiring each home health agency to submit to, the Secretary such data that the Secretary determines are appropriate for the measurement of health care quality for 2007 and each subsequent year. Section 5201 (c)(v) requires a payment adjustment if a home health agency does not submit data for the reporting year, "the home health market basket percentage increase applicable for such year shall be reduced by 2 percentage points. The 2 percent reduction would begin to apply to annual payment updates beginning on January 2007 and each year thereafter. For CY 2010 the data will be will based on OASIS submissions from 7/1/2008-6/30/2009.

The law also requires the Secretary to establish procedures for making data submitted available to the public and ensures the home health agency has the opportunity to review the data prior to the data being made public. HHAs currently have pre-publication access to their own agency's quality data (which the contractor updates periodically). We propose to continue this process, to enable each agency to know how it is performing before public posting of data on the Home Health Compare Web site. CMS also publishes an annual "Preview Report in fall of each year available to home health agencies on the Casper Reporting system and posted the memorandum in the OASIS State Welcome Page in their folders to advise them of the preview reports and how to access them. (See QTSO Memorandum 2006-122, published November 17, 2006 in the Downloads section below.) (See Pay for Reporting Implementation Links and Downloads below for the original DRA, Rule and Press Release)

The Secretary has determined that the OASIS information collection best meets the requirements of this statutory mandate. Continuing to use the OASIS instrument ensures that providers will not have an additional burden of reporting through a separate mechanism and that the costs associated with the development and testing of a new reporting mechanism can be avoided.

Therefore, OASIS assessment episodes submitted by Home Health Agencies to CMS for Condition of Participation compliance for dates of service beginning July 1 and ending June 30 of each year will count as meeting the reporting requirement for CY as listed in the rules for annual payment update. (This reporting time period would allow 12 full months of data and would provide us the time necessary to analyze and make any necessary payment adjustments.) We propose to reconcile the OASIS submissions with claims data every year in order to verify full compliance with the quality reporting.

HHAs that meet the reporting requirements would be eligible for the full home health market basket percentage increase. We proposed that home health agencies certified on or after May 1, each year for payments to be made in the next calendar year to be excluded from the quality reporting requirement data for use in that CY, as data submission and analysis would not be possible for an agency certified this late in the reporting time period. At the soonest time possible after obtaining the CCN number, reporting is mandated. We note these exclusions only affect quality reporting requirements and do not affect the agency's OASIS reporting responsibilities under the CoP submission requirement. The data elements will not require additional reporting or burden to HHAs.

Additionally, section 1895(b) (3) (B) (v) (II) of the Act provides the Secretary with the discretion to submit appropriate health care quality data in a form, manner, and time specified by him. Such measures would be evidence-based, clearly linked to improved outcomes, and able to be reliably captured with the least burden to the provider.

The OASIS Version C has undergone final revisions based on OMB public comment period and the NQF steering committee process. The implementation of OASIS Version C is anticipated to begin collection in 2010 with HH Compare display of new and refined measures in 12/2010 for a 2011 P4R impact. There will be a transition of measure requirements as the data elements and quality measures change. CMS will indicate in rulemaking the transition of measures it plans to post on Home Health Compare. Some measures may continue to be reported, while others will be new and refined, and others retired. Measure priorities are determined with each annual payment update - NPRM.

Proposed Reporting of Quality Data

CMS proposes payment changes for Medicare Home Health Services and in reporting quality data for each calendar year through the Rulemaking Process (NPRM)(See Related Links Within CMS below Additional information can be found in the Downloads or Related Links Within CMS section below.

Downloads
Pay for Reporting Implementation 2005-2007 [ZIP 1.3 MB]

Section 5201 of the Deficit Reduction Act of 2005 [PDF 43 KB]
Related Links Inside CMS
CMS-154-Proposed Rule - Home Health Prospective Payment System

Home Health PPS

Press Release - November 1, 2006
Related Links Outside CMSExternal Linking Policy
There are no Related Links Outside CMS.

 

 

Page Last Modified: 02/11/2009 2:44:21 PM
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