Mark Tarr, chief operating officer of HealthSouth Corp., Birmingham, Ala., said the quality program and its elements were not a surprise. “We applaud the push,” he said. The areas of initial focus by the quality program are also priorities for HealthSouth, and company officials are OK with the measures selected, Tarr said.
Of the two measures already proposed by the CMS, one targets catheter-associated urinary-tract infections, a measure endorsed by the NQF for hospitals, but one that the CMS believes applies to the inpatient rehab setting, according to the proposed rule. The CMS proposes that reporting on this measure be done through the Centers for Disease Control and Prevention's National Healthcare Safety Network, beginning Oct. 1, 2012.
The other measure currently proposed concerns the percentage of patients with new or worsened pressure ulcers, an NQF measure designed for nursing homes. The CMS intends to ease the reporting requirement for this measure by modifying the reporting requirements for the existing Inpatient Rehabilitation Facility-Patient Assessment Instrument, according to the rule. The third measure still under consideration for use would be a 30-day comprehensive, all-cause risk-standardized readmission measure, which could be calculated using claims data already submitted, if it is included in the program.
Comment on the three measures will be accepted by the CMS until June 21 and a final rule will be published by Aug. 1.
Hospices, meanwhile, would be required to submit quality data measures to the CMS or else have their annual increase reduced by 2 percentage points beginning in fiscal 2014.
One of those measures—endorsed by the NQF—would measure the percentage of patients who experienced pain on admission to a hospice and whose pain was brought under control within 48 hours, according to the rule.
The other is a proposed structural measure that relates to participation in a quality assessment and performance improvement program. “We believe that participation in QAPI programs that address at least three indicators related to patient care reflects a commitment not only to assessing the quality of care provided to patients but also to identifying opportunities for improvement that pertain to the care of patients,” the CMS said in its 151-page rule. The agency said examples of these “domains of indicators” include providing care in accordance with documented patient and family goals, effective and timely symptom management, care coordination and patient safety.
Meanwhile, the rule would change how hospice patients are counted in 2012. While the current law requires the CMS to impose a limit on the aggregate Medicare payments a hospice provider receives annually, the rule would change the current calculation and also apply that method to past years in certain instances. But it would also give hospice providers the opportunity to maintain their current counting methodology.
Finally, the proposed rule would change the “face-to-face encounter” requirement by removing the stipulation that the hospice physician who performs the face-to-face encounter with the patient must be the same physician who certifies the patient's terminal illness.
The CMS will accept comments on the hospice rule until June 27.
“Our first impression is that CMS has taken a very measured and thoughtful approach to its plans for hospice quality reporting,” Theresa Forster, vice president for hospice policy and programs at the National Association for Home Care and Hospice, said in an e-mailed statement. “They appear to be mapping out a strategy for the future that uses requirements in the 2008 conditions of participation as a foundation—which will allow hospices to build off of existing practice and adapt to the change more readily.”
—with Jessica Zigmond