CMS Proposes to Increase Assessment Items for Cognition

As NAHC Report readers know, the Centers for Medicare & Medicaid Services (CMS) published in the Federal Register on July 28, 2017 the Calendar Year (CY) 2018 Home Health Prospective Payment System Rate Update proposed rule.

A significant portion of the proposed rule is dedicated to proposals that update the Home Health Quality Reporting Program (HH QRP). The changes are numerous, with the majority focused on cross setting quality measures and standardized assessment items that CMS is required to develop in accord with the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act). (Please see this relevant NAHC Report article.)

In order to meet the requirement of the IMPACT Act to develop standardized assessment items that capture cognitive function and impairments, CMS proposes to add three new assessment items:

  • Brief Interview for Mental Status (BIMS)
  • The Confusion Assessment Method¬† (CAM)
  • Behavior Signs and Symptoms

The BIMS is a nine-question item that assesses cognition through repetition and recall with and without prompting, and temporal orientation.

The CAM is a six-question item that screens for overall cognitive impairment, as well as distinguishes delirium or reversible confusion from other types of cognitive impairment.

The Behavior Signs and Symptoms assessment item consists of three questions that assess whether the patient has exhibited any behavioral symptoms that may indicate cognitive impairment or other mental health problem including physical, verbal, and other disruptive or dangerous behavioral symptoms.

To view the proposed standardized assessment items for cognition and behavior click here.

The proposed assessment items for cognitive function and behavior evaluated in isolation are acceptable assessment items for home health patients. However, CMS is proposing to add all three items to the Outcome and Assessment Information Set (OASIS) data set.  In total this would add 18 assessment items. In addition, CMS is not proposing to remove the current OASIS items that assess cognition (M01740) and behavior (M01745). (Please see this relevant NAHC Report article.) The inclusion of the three proposed assessment items for cognition and behavior wouldcreate additional burden for data collection without any added benefit.

The National Association for Home Care and Hospice (NAHC) intends to construct its comments on the proposed standardized assessment items for cognition and behavior around the burden for implementation if all three assessment items are finalized, in addition to the overlap with the current OASIS assessment items.

Comments on the proposed rule are due September 25, 2017. Stay tuned for more from NAHC Report.