Important Changes on the Horizon

The following summarizes important changes on the horizon for Home Health and Hospice agencies as reported by Centers for Medicare and Medicaid Services (CMS) and National Association for Home Care (NAHC) representatives at the National Association for Home Care’s March on Washington Conference and Exhibition, March 23-26, 2014, Washington, DC:

Home Health

The home health industry has been waiting since 1997 for revised Conditions of Participation (CoPs) to be released. CMS Survey and Certification representatives reported the revised CoPs will be released in Federal Register in the next few weeks as a proposed rule (statute requires proposed rules that have not been finalized within a three-year timeframe to be re-released as proposed rule).  This will allow the home care industry time to review the proposed rules and provide feedback during the open comment period.  MedForms is monitoring this process and will recommend suggested changes to your Orientation Booklets, based on any new regulations, once the proposed rules have been finalized.

The revised OASIS C-1 data set will be implemented October 1, 2014.  As of that date, MedForms will no longer offer OASIS forms for purchase.  We have been in communication with Briggs Corporation regarding this decision and recommend them as a source for your future OASIS C-1 needs.  Briggs is in the process of updating their current OASIS forms and will have them available on their website, once completed.  You may view their OASIS forms online here.

You may also call Briggs at 1-800-247-2343 and ask for an account manager to assist you with your needs.

Hospice

As part of the Hospice Quality Reporting Program mandated by the Affordable Care Act (ACA), CMS has developed the Hospice Item Set (HIS) for the purpose of collecting uniform data associated with quality measures specific to hospice care. This new data collection requirement becomes effective July 1, 2014 and will require hospices to collect data elements at admission and discharge.  The HIS data elements are quality measures endorsed by the National Quality Forum (NQF) and include: 1) NQF #1617 – Patients treated with opioids who are given a bowel regimen; 2) NQF #1634 – Pain screening; 3) NQF # 1637 – Pain assessment; 4) NQF # 1638 – Dyspnea assessment; 5) NQF # 1639 – Dyspnea screening; 6) NQF # 1641 – Treatment preferences; and 7) NQF # 1647 – Beliefs/Values addressed (if desired by the patient).

According to CMS’ HIS Fact Sheet, HIS is not a patient assessment instrument and will not be administered to the patient and/or family, but rather is a standardized mechanism for abstracting data from the medical record; therefore, MedForms will not offer suggested changes to Hospice Orientation Booklets based on HIS.  Hospices will be required to transmit HIS data to CMS through electronic means.  CMS plans to release free software (HEART) for transmission of the HIS data in May 2014.  Additional information and user manuals may be found here.

Hospice Experience of Care Survey: Much like the HHCAHPS survey process for home health agencies, hospices will be required to participate in the Experience of Care Survey by contracting with a CMS-approved vendor, effective April 1, 2015.  A draft Experience of Care Survey is currently being piloted and the final version is expected to be released by CMS this fall.  Hospices will submit a list of discharged patients to their vendor each month and the vendor will be responsible for conducting surveys and transmitting aggregate data to CMS. Although required monthly transmissions begin April 1, 2015, vendors will submit a dry-run for first quarter of 2015.  There will be a financial penalty for hospices that choose not to participate in the Experience of Care Survey (hospices with less than 50 patients will be exempt).  Once the CMS- approved vendor list is publicized, MedForms will ask for your vendor name and incorporate this information into your Hospice Orientation Booklet as a suggested change.  For more information, please go here.

Cathy Green, RN

Vice President of Regulatory Affairs • MedForms®, Inc.

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