May Insights and Critical Updates (V.1)
CHAP is always seeking resources and insights to enhance the knowledge of partners and customers. Today, we share a recent federal information update.
Hospice Updates
GAO report – Medicare Hospice: CMS Needs to Fully Implement Statutory Provisions and Prioritize Certain Overdue Surveys (GAO-24-106442)
Report Fast Facts
Medicare is required to monitor hospices through surveys every 3 years. Surveys can find serious quality issues, raising concerns about the adequacy of care and triggering additional monitoring. About 15% of hospices were cited with serious quality issues from 2020 through 2022. Medicare is working on, but hasn’t fully implemented, enforcement tools—such as fines—to help bring hospices like these into compliance.
In addition, as of May 2023, about 10% of hospices were overdue for a survey—partly due to funding and staffing issues at the state agencies that conduct these surveys. The GAO recommended addressing these and other issues we found.
Read the report – https://www.gao.gov/products/gao-24-106442
Home Health Updates
Draft OASIS E-1 Manual and Instruments
The draft Guidance Manual for the OASIS-E1 version of the OASIS data set, effective January 1, 2025, is available in the Downloads section of the OASIS User Manuals | CMS page, https://www.cms.gov/medicare/quality/home-health/oasis-user-manuals. The draft OASIS-E1 Instruments (All Items and Time Points versions) are available in a zip file in the Downloads section of the OASIS Data Sets | CMS page, https://www.cms.gov/medicare/quality/home-health-oasis-data-sets.
CMS posted draft Version E1 of the OASIS data set effective January 1, 2025:
More Information:
OASIS Data Sets webpage
OASIS User Manuals webpage
April 2024 Interim Performance Reports (IPRs) are Available on iQIES
The Preliminary April 2024 Interim Performance Reports (IPRs) for the expanded HHVBP Model have been published on the Internet Quality Improvement and Evaluation System (iQIES). The quarterly IPRs provide HHAs with the cohort assignment, performance year measure data for the 12 most recent months, and interim Total Performance Score (TPS). Using the IPR, an HHA can assess and track their performance relative to peers in their respective cohort throughout the expanded Model performance year.
An HHA will receive an IPR for the calendar year (CY) 2023 performance year if the HHA:
- Was Medicare-certified prior to January 1, 2022, and
- Meets the minimum threshold of data for at least one (1) quality measure in the quarterly reporting period for the performance year shown in Exhibit 1.
IPRs are available via iQIES in the “HHA Provider Preview Reports” folder, by the CMS Certification number (CCN) assigned to the HHA. If your organization has more than one (1) CCN, then a report will be available for each CCN. Only iQIES users authorized to view an HHA’s reports can access expanded HHVBP Model reports. For assistance with downloading your HHA’s IPR, please contact the iQIES Service Center at 1-800-339-9313, Monday through Friday, 8:00 AM-8:00 PM ET, or by email (iqies@cms.hhs.gov). To create a ticket online or track an existing ticket, please go to CCSQ Support Central.
All Provider Updates
HHS Posts Nondiscrimination in Health Programs and Activities Final Rule
On April 26, 2024, the Department of Health and Human Services (HHS), under its Office of Civil Rights (OCR), released a final rule under Section 1557 of the Affordable Care Act (ACA). The final rule will be posted in the Federal Register on May 6, 2024. Access is available now in the Federal Register at https://www.govinfo.gov/content/pkg/FR-2024-05-06/pdf/2024-08711.pdf
It is critical for all providers to carefully review the content in the final rule to understand the regulatory requirements and compliance timeline.
Alternative effective dates table for specific provisions was updated on 5/8/2024.
Read the CHAP blog which includes highlights about provider requirements – https://chapinc.org/blog-news/hhs-posts-nondiscrimination-in-health-programs-and-activities-final-rule/
Revisions to the State Operations Manual (SOM) Chapter 10 –Informal Dispute Resolution (IDR) and Enforcement Procedures for Home Health Agencies and Hospice Programs
The Centers for Medicare & Medicaid Services (CMS) revised the State Operations Manual (SOM) chapter 10 to provide procedures regarding the informal dispute resolution (IDR) process for both Home Health Agencies (HHAs) and hospice programs.
Revisions also include guidance for State Agencies (SAs) and CMS Survey & Operations Group (SOG) Locations on recommending and imposing HHA alternative sanctions and hospice enforcement remedies.
Read the memo – https://www.cms.gov/files/document/qso-24-11-hha-hospice.pdf
CHAP policies/procedures were updated at the effective date of this regulatory requirement and approved by CMS.
Final Rule to Establish First-Ever Regulations for Adult Protective Services
HHS) through the Administration for Community Living (ACL), announced a final rule to establish the first federal regulations for Adult Protective Services (APS). The new regulations promote high-quality APS and will improve consistency in services across states. With the final rule, ACL aims to support the national network that delivers APS, with the ultimate goal of better meeting the needs of adults who experience, or are at risk of, maltreatment and self-neglect.
The APS final rule:
- Establishes a set of national minimum standards for the operation of APS programs that all state APS systems must meet – and encourages states to exceed them.
- Requires APS systems to ensure that planning and delivery of all services respect the fundamental right of adults to make their own life choices and that services are driven by the person receiving them.
- Establishes stronger protections for clients subject to, or at risk of, guardianship.
- Requires response within 24 hours of screening to cases that are life-threatening or likely to cause irreparable harm or significant loss of income, assets, or resources.
- Requires APS to provide at least two ways – at least one online – to report maltreatment or self-neglect 24 hours per day, seven days per week.
- Requires robust conflict of interest policies to support ethical APS practice.
- Establishes definitions for key APS terms to improve information sharing, data collection and program standardization.
- Promotes coordination and collaboration with state Medicaid agencies, long-term care ombudsmen, tribal APS, law enforcement and other partners.
Review the rule – https://www.govinfo.gov/content/pkg/FR-2024-05-08/pdf/2024-07654.pdf
Update to CMS National Quality Strategy: Quality in Motion
The CMS National Quality Strategy (NQS) cross-cutting initiative was launched in 2022 with a goal of improving the quality and safety of health care for everyone, focusing on those from underserved and under-resourced communities. The four priority areas (Outcomes & Alignment, Equity & Engagement, Safety & Resiliency, and Interoperability & Scientific Advancement) of the CMS National Quality Strategy guide us to move the needle on quality of care. Quality in Motion: Acting on the CMS National Quality Strategy is CMS’s latest update to the National Quality Strategy, highlighting CMS’ progress in these priority areas. To advance the NQS goals, CMS welcomes collaboration from government partners, healthcare payers and providers, and community-based organizations, as well as all individuals, families, caregivers, and communities. The new plan includes a three-part call to action:
- Adopt the Universal Foundation measure sets across quality and value-based programs, including the newly published hospital, maternity care, and post-acute care/long-term care add-on sets.
- Commit to improving health care safety and reducing harm.
- Advance health equity in all quality and value-based programs.
Quality in Motion outlines opportunities for CMS to partner with you to build on our shared mission of optimal health and well-being for all individuals. We encourage you to read the action plan and discover ways we can partner together to promote high-quality health care. Please reach out to QualityStrategy@cms.hhs.gov to collaborate! Together we can put quality in motion!
Mental Health: It’s Important at Every Stage of Life
Mental and physical health are equally important components of overall health. For example, depression increases the risk for many types of physical health problems, particularly long-lasting conditions like diabetes, heart disease, and stroke (see CDC). During Mental Health Awareness Month, recommend appropriate preventive services, including:
Resource of Health Equity-related Data Definitions, Standards, and Stratification Practices
CMS released a resource document (PDF) of health equity-related data definitions, standards, and stratification practices.
More Information: