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Federal Updates for Home Health and Hospice

Expanded Home Health VBP Resources. Members are encouraged, if you have not already done so, to subscribe to the Centers for Medicare and Medicaid Services' (CMS) Expanded Home Health Value-Based Purchasing (VBP) Model newsletter. The October 2022 issue is available here. Significant resources on the new program, which goes into effect January 2023, are here.

CMS Announces Hospice Care Compare Off-Cycle Refresh. CMS has announced an off-cycle refresh for the Hospice Quality Reporting Program (HQRP) available on Care Compare in October 2022. This off-cycle refresh will include the addition of HQRP and Hospice Care Index (HCI) informational videos, which can be viewed on Care Compare, and removal of references to Hospice Annual Payment Update (APU) Compliance. No quality measure reporting has been updated.

CMS Issues Updated Quarterly OASIS Q&As. CMS has released October 2022 Outcome and Assessment Information Set (OASIS) Questions and Answers (Q&As). This document is updated on a quarterly basis and is intended to provide guidance on OASIS questions that were received by CMS help desks. As a reminder, responses may be time-limited and may be superseded by future CMS guidance. This quarterly guidance includes clarifications on the following items:

Completing RFA 6 – Transferred to an inpatient facility, patient not discharged from agency: If a patient is recertified for home health, but no visits are made prior to the individual being admitted for a qualifying inpatient stay, the agency should complete a Transfer assessment whether or not any visits were made in the new episode.

New OASIS Item Data Collection (A1005, A1010, A110, A1250, B1300, D0700): Based on coding guidance, the medical record should not be used as the data source for coding Health Literacy (A1250) and Social Isolation (B1300). The medical record can be used for coding Ethnicity (A1005), Race (A1010), Language (A1110), and Transportation (1250) ONLY IF the patient and/or proxy are unable to respond during the Start of Care (SOC)/Resumption of Care (ROC) or discharge assessment time periods.

A1250, B1300 – Transportation and Health Literacy: An example was requested of how these items might be different at SOC/ROC to Discharge. CMS clarified that clinicians must consider each patient’s unique circumstances and use clinical judgment to determine how transportation and health literacy apply to each individual. It is possible that the SOC/ROC and discharge coding are the same.

C0200-C0500 – BIMS: To support patients who are hearing impaired, agencies may develop their own process for how to administer the Brief Interview for Mental Status (BIMS) in writing (e.g., on a laptop vs. paper/card format), but whatever process the agency decides to implement, it must use the exact language as that in the item test.

J0520 – Pain interference with therapy activities: CMS clarifies that while the definition of “Rehab Therapy” states the “special healthcare services or programs that help a person regain physical, mental and or cognitive abilities,” treatment is not limited to this regardless of the rehab focus or goals including maintenance therapy.

K0520 – Nutritional Approaches: At SOC/ROC and discharge, check all of the nutritional approaches as part of the current care/treatment, even if not used during the time period under consideration for SOC/ROC and discharge. At discharge, agencies do not report on nutritional approaches occurring after discharge.

N0415 – High Risk Drug Classes: Use and Indication: Medications should be coded according to the medication’s therapeutic category and/or a pharmacological classification. CMS does not specify a source for identifying the therapeutic category and or/pharmacological classification.

N0415 – High Risk Drug Classes: Use and Indication: At discharge, N0415 considers medications included in the patient’s prescribed drug regimen at discharge, even if it was not taken on the day of assessment, and not what is expected to occur after discharge.

O0110 – Special Treatments, Procedures, and Programs: CMS clarifies that agencies should check all treatments, programs, and procedures that are part of the patient’s current care/treatment plan during the SOC/ROC assessment and the discharge assessment, even if not received during the SOC/ROC or discharge time period under consideration. Do not consider what is expected to occur after discharge. Include all treatments, programs, and procedures performed by others and those the patient performed themselves independently or in any other care setting such as dialysis facilities.

O0110 – Special Treatments, Procedures, and Programs: Oxygen Therapy: Regardless of how oxygen is ordered, including PRN, apply the OASIS-specific definitions in determining whether oxygen is coded as continuous or intermittent.

O0110 – Special Treatments, Procedures, and Programs: Non-Invasive Mechanical Ventilator BiPAP/CPAP: While sometimes a patient may be ordered a bilevel positive airway pressure (BiPAP)/continuous positive airway pressure (CPAP) machine, but they refuse to wear it, if it is part of the patient’s current care/treatment plan, then mark O0110G1 – Non-Invasive Mechanical Ventilator and O0110G2 – BiPAP or O0110G3 – CPAP.

CMS Releases HQRP Quarterly Update for Third Quarter of 2022. The Hospice Quarterly Update for the third quarter of 2022 is now available. This update includes HQRP highlights from July to September 2022, events and engagement opportunities for the fourth quarter of 2022 (October to December 2022), and selected Q&As from the Hospice Quality Help Desk regarding timing of the new claims-based measures and responding to letters of non-compliance. Please navigate to the HQRP Requirements and Best Practices page to download this document.

Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871