The Centers for Medicare and Medicaid Services (CMS) held a Home Health, Hospice, and DME Open Door Forum on November 9, 2022. What follows is a summary of the relevant ODF content for home health and hospice providers. HOME HEALTH CMS began the Forum with a summary of the CY 2023 Home Health Prospective Payment…
The hospice quality reporting program (HQRP) quarterly update has been recently posted, including a reminder that the HQRP annual payment update penalty for providers not compliant with calendar year 2022 submission requirements jumps from two percent to four percent.
In addition, there are updates related to public reporting, Q&A, and new HQRP resources among other updates. In addition to the quarterly update, there are a few items of note related to the HQRP.
- Hospices are reminded that the Hospice Visits in Last Days of Life (HVLDL) and the CAHPS Hospice Survey Star Rating will be posted to Care Compare this month. As reported previously, these measures were to be publicly reported in May of this year but were delayed due to an error in the provider preview reports.
- The HVLDL was formally endorsed by the National Quality Forum (NQF) at the end of July. NAHC and others submitted comments to the NQF about concerns with the HVLDL, primarily that it does not represent the care being provided to beneficiaries since it includes only RN and SW visits and does not include telehealth visits. We included concerns in our comments to the NQF about the data used by the Centers for Medicare and Medicaid Services (CMS) in deciding which types of visits should be included in the measure. While NQF ultimately endorsed the measure it recommended that CMS continue to develop the measure. Comments submitted that highlighted the concerns about the measure were an important component to this recommendation. NAHC also shared concerns about the HVLDL in the response to the FY2023 hospice proposed wage index and payment update and quality reporting program update rule. CMS acknowledged the comments in the final rule and indicated it is considering these comments.
- Notification to non-compliant hospice providers based on their CY 2021 quality data impacting FY 2023 payments was disseminated in July. Providers can find the notifications in their CASPER folders and should receive a notification from their Medicare Administrative Contractor (MAC). Providers have thirty (30) days from the date on the notification of non-compliance to submit a request for reconsideration. More information on the timeline for this process can be found in the quarterly update and on the CMS HQRP Reconsideration Requests webpage.
- Hospices are reminded that the Hospice quality reporting data submitted in CY 2022 data, starting on January 1, 2022 impacts FY 2024 payments. Beginning with FY 2024, the APU penalty doubles, going from 2% to 4%, for hospices not meeting the HQRP requirements. To ensure hospices achieve the full APU, be certain to meet the quality reporting requirements for data submission in CY 2022:
|Annual Payment Update||HIS||CAHPS|
|FY2024||Submit at least 90 percent of all HIS records within 30 days of the event date (patient’s admission or discharge) for patient admissions/discharges occurring 1/1/22 – 12/31/22.||Ongoing monthly participation in the Hospice CAHPS survey 1/1/2022 – 12/31/2022|
Most hospices that receive the APU penalty do so because of noncompliance with the Hospice Item Set (HIS) submission requirements. This frequently occurs during changes in EHR systems and changes in staffing so hospices should be sure to confirm submission of the HIS timely by downloading the Final Validation Reports. This report identifies HIS submissions received by CMS, and this receipt must occur in order for the hospice to receive “credit” for having submitted the HIS.
5. CMS has added some new resources for the HQRP which are below. CMS also indicated that it plans to host a Forum in September, but no dates have been provided yet. Stay tuned to NAHC Report for more information as it becomes available.
A) Hospice Care Index (HCI) Explanatory Video: CMS has developed a new video resource explaining the purpose and design of the claims-based HCI quality measure. This video provides an overview of the new HCI claims-based measure, which combines several quality indicators into a single index score.
B) HQRP Explanatory Video: The video introduces the purpose of the HQRP, how data is collected for use in HQRP, and the quality measures included in HQRP.
The hospice quality reporting program (HQRP) quarterly update has been recently posted, including a reminder that the HQRP annual payment update penalty for providers not compliant with calendar year 2022 submission requirements jumps from two percent to four percent. In addition, there are updates related to public reporting, Q&A, and new HQRP resources among other…
Last month, the Centers for Medicare & Medicaid Services (CMS) announced that the Hospice Visits in the Last Days of Life (HVLDL) and the Hospice Care Index (HCI) claims-based measures were not publicly displayed as planned in the May 2022 refresh. NAHC reached out to CMS about this and learned that there were technical errors in the data calculation, which were discovered well after the Preview Reports for these measures were released to hospices in March.
CMS is mandated to give providers a full 30 days to review the Preview Reports. Because of this, there was not time to re-release Preview Reports prior to the planned May 2022 refresh. Hospices should disregard the Preview Reports released in March for the HVLDL and HCI.
CMS is targeting the August 2022 refresh for the inaugural display of these quality measures and announced that new Provider Preview Reports for the HVLDL and HCI are now available in hospice’s CASPER (Certification and Survey Provider Enhanced Reports) folder.
Hospices utilized data from the incorrect scores in the Preview Reports to plan for performance improvement and they may have to adjust their priorities and plans now that the new Preview Reports are available.
The recently available provider Preview Reports also contain the Preview Reports for other publicly reported measures that will be updated in the August 2022 Care Compare refresh. These include the CAHPS Hospice Star Rating and the HIS Comprehensive Assessment measure.
Once released in CASPER, providers will have 30 days during which to review their quality measure results. Although the actual “preview period” is 30 days, the reports will continue to be available for another 30 days, or a total of 60 days. The preview period for the latest Provider Preview Report lasts from May 25, 2022 to June 27, 2022.
CMS encourages providers to download and save their Hospice Provider Preview Reports for future reference, as they will no longer be available in CASPER after this 60-day period.
Last month, the Centers for Medicare & Medicaid Services (CMS) announced that the Hospice Visits in the Last Days of Life (HVLDL) and the Hospice Care Index (HCI) claims-based measures were not publicly displayed as planned in the May 2022 refresh. NAHC reached out to CMS about this and learned that there were technical errors…
- CAHPS Star Rating
- CASPER toolkit
- HIS, HCI, HVLDL
A CAHPS Hospice Survey Star Rating will be added to Care Compare for hospices with the August 2022 refresh. How the star rating is calculated, what will be publicly reported, and information about the current “dry run” and provider preview information are part of the overview. Stay tuned to NAHC Report for member resources on the CAHPS Hospice Survey Star Rating.
The Centers for Medicare & Medicaid Services (CMS) conducted an overview of the star rating in a webinar on December 16, 2021 and the materials from the webinar – slide deck, transcript, and recording — are now available here.
CMS also updated and rebranded a provider toolkit for hospices, Getting Started with Hospice CASPER Quality Measure Reports: February 2022. The toolkit is to assist hospice providers in understanding and using the CASPER Quality Measure (QM) Reports that now include claims-based measures. There are two reports:
- The Hospice-Level QM Report includes the HIS Comprehensive Assessment at Admission (NQF #3235), HCI, and HVLDL measure scores.
- The Hospice Patient-Level QM Report identifies each patient with a qualifying HIS record used to calculate the hospice-level quality measure values for a select period.
The reports are detailed, and hospices may be especially interested in the Hospice Care Index (HCI) and Hospice Visits in Last Days of Life (HVLDL) information.
NAHC conducted a webinar on these measures in December where we reviewed the most frequently asked questions about the HVLDL and explained the HCI – each of its ten indicators, calculation of the index score, and expected performance for each of the indicators and the index. Information from the webinar and from a hospice’s QM reports are helpful for performance improvement. The recording of the webinar is available here.
CAHPS Star Rating CASPER toolkit HIS, HCI, HVLDL A CAHPS Hospice Survey Star Rating will be added to Care Compare for hospices with the August 2022 refresh. How the star rating is calculated, what will be publicly reported, and information about the current “dry run” and provider preview information are part of the overview. Stay tuned…
A Centers for Medicare & Medicaid Services’ (CMS) webinar on the CAHPS hospice star rating on December 16, 2021 revealed additional detail about the rating, which will be publicly reported on Care Compare beginning in August 2022. CMS is calling this star rating the “Family Caregiver Survey Rating Summary Star” and it will range from one star (worst) to five stars (best).
CMS will calculate nine CAHPS Hospice Star Ratings: one for each of the eight publicly reported CAHPS Hospice measures and a Family Caregiver Survey Rating, which is a summary star rating that combines the star ratings of the eight family caregiver experience measures. Only the CAHPS Hospice Summary Star Rating will be publicly reported on Care Compare and only those hospices with 75 or more completed surveys over the reporting period will have their star rating publicly reported. The rating will be updated every other quarter (every 6 months). CMS is using the February 2022 and May 2022 Care Compare refresh period as a “dry run”. This allows hospices to see their star ratings and what the summary star rating would be if it were to be posted on Care Compare.
Again, CMS will not post the Star Rating on Care Compare until August 2022. Hospices can see their first “dry run” ratings in their CMS Preview Report that became available in November 2021. This is an “on demand” report so it does not automatically appear in the CASPER folder. Hospices need to run the report from the “Hospice Quality Reporting Program” report category. The reporting period for the dry run is October 1, 2018 – December 31, 2019; July 1, 2020 – March 31, 2021. More information about how to access the Star Rating Preview Report is found in the Hospice Quality Reporting Measure Specifications User’s Guide.
During the webinar, CMS explained the calculation of the star rating, which is similar to calculations CMS uses in other quality reporting programs. Top-box scores, the proportion of respondents who gave the most favorable response(s) for each of the CAHPS Hospice Survey measures that are publicly reported, are used and adjusted for the case mix of the hospice and mode of survey administration. CMS intended with the calculation to have maximal differentiation between the star categories and to have minimal differentiation of hospices within the star category making the star rating more meaningful. Detailed information regarding the calculation can be found in the CAHPS Star Rating Technical Notes.
A little more than 2000 hospices met the eligibility criteria to be assigned a star rating for the dry run period. This is not an overwhelming majority of hospices so it is possible there are pockets where only some of the hospices will have a publicly reported Star Rating which may make comparison among hospices confusing. Approximately 90 percent of Medicare beneficiaries enrolled in hospice in 2020 were enrolled in a hospice that does have a Star Rating during the dry run.
The slides and recording of the December 16 webinar will also be available soon on the CMS Hospice Quality Reporting webpage. Additionally, NAHC is developing a resource for providers which will be available at the beginning of 2022.
Due to an issue identified with the national averages and percentile calculations for the Hospice Care Index (HCI) measure, CMS revised the data for the HCI Preview Reports. Hospices are able to access these revised reports via the Hospice Quality Reporting Program category in their CASPER folders now.
CMS is targeting the May 2022 refresh for the inaugural public display of the HCI and Hospice Visits in the Last Days of Life (HVLDL) claims-based measures. The eight quarters of claims data used to calculate these measures for a May 2022 refresh would include Q2 2019–Q4 2019 and Q3 2020–Q3 2021. CMS is also planning to provide annual updates to the claims-based measures in November 2022 and each following November refresh. Learn more about HCI and HVLDL in the Q&A on Claims-Based Measures downloadable (PDF) located on the Background and Announcements webpage.
HQRP TIP SHEETS
CMS updated the Hospice Quality Reporting Program (HQRP) resources on December 16 by posting two new Tip Sheets
Second Edition HQRP Public Reporting Tip Sheet
HQRP Compliance Tip Sheet_ FY 2022 and Future Years
The Second Edition HQRP Public Reporting Tip Sheet explains how CMS will handle the impact of the temporary exemption of quality reporting that occurred due to the COVID-19 Public Health Emergency (PHE) in the HQRP going forward and incorporates the changes to the HQRP from the FY 2022 hospice final rule. The HQRP Compliance Tip Sheet_FY 2022 and Future Years provides information on the HQRP, compliance requirements and how to track compliance.
A Centers for Medicare & Medicaid Services’ (CMS) webinar on the CAHPS hospice star rating on December 16, 2021 revealed additional detail about the rating, which will be publicly reported on Care Compare beginning in August 2022. CMS is calling this star rating the “Family Caregiver Survey Rating Summary Star” and it will range from…
If you missed this webinar, which aired live on November 30, you can still watch it.
- Free to NAHC members!
Two new claims-based measures will be publicly reported in 2022 – HCI and HVLDL. The HCI is brand new to hospices and includes ten different indicators of performance comprising the Index. It is a measure that is complex and utilizes hospice claims data over a two-year period. Hospices have many questions about each of the ten indicators, calculation of the Index score, and expected performance for each of the indicators as well as the Index. This session will focus primarily on these aspects of the HCI and what hospices should be addressing in daily operations to impact the HCI, but will also include a review of the HVLDL and its most frequently asked questions.
- Describe the HCI measure and each of its ten indicators
- Explain the performance calculations for the ten HCI indicators and the Index
- Share a forecast of the expected public reporting timeframe for the HCI
- Provide suggestions for preparing for public reporting and performance improvement
- Review the HVLDL most frequently asked questions
- Katie Wehri, Director of Home Health & Hospice Regulatory Affairs, NAHC
- Jennifer Hale, MSN BS RN CHPN, Vice President, Clinical Quality and Standards, Compassus
- Members: Free
- Non-members: $99