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Impact act of 2014. David Gifford S VP Quality & Regulatory Affairs Congressional briefing Washington DC June 23 rd , 2014. “IMPACT ACT OF 2014” . Legislation has four parts : Incorporate standardized assessment Public reporting of common quality measures
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Impact act of 2014 David Gifford SVP Quality & Regulatory Affairs Congressional briefing Washington DC June 23rd, 2014
“IMPACT ACT OF 2014” Legislation has four parts : • Incorporate standardized assessment • Public reporting of common quality measures • Provide quality measures to consumers when transitioning to a PAC provider • HHS and MedPAC to conduct several
“IMPACT ACT OF 2014” Part 1 • Incorporate standardized assessment(s) (e.g. CARE tool) into existing assessment tools across PAC providers (LTCH, IRF, SNF, & HH) and acute care hospitals for • Pressure ulcers • Functional status • Cognitive status • Special Services • Collect data at admission and discharge • Applies also to acute care hospitals
“IMPACT ACT OF 2014” Part 2 • Develop & Publicly report quality measures across settings • Rehospitalizations & hospitalizations • Hospitalizations after discharge from PAC provider • Discharge to community • Pressure ulcers • Medication reconciliation • Incidence of major falls • Patient preferences • Efficiency measure(s): Avg Total Medicare Spend per Beneficiary • Plus any other measures Secretary wants • Measures must be approved by National Quality Forum • Public reporting starting in Oct 2018
Using information across settings • Clinical Care • Quality Improvement • Accountability measurement • Public reporting • Network selection • Payment (e.g. Value Based Purchasing) • Policy evaluations & decisions
Questions to ask about measures • Data source • Is it reliable and valid? • Is consistent and comparable • Wording of assessment • Rating scale used • Frequency of assessment • Measure definition • Who does the measure apply to (e.g. denominator) • Who is counted in the measure (e.g. numerator) • Does the measure need to be risk adjusted? • What are clinical and non-clinical characteristics used in risk adjustment • Is the measure reliable and valid? • How to compare providers based on measure results • How do you use measure results for • Quality improvement • Network selection • Payment
Rating of questions IRF OASIS 0 = able to bath self independently 1 = with the use of devices, is able to bath self 2 = able to bathe in shower or tub with the intermittent assistance of another person 3 = able to participate in bathing self in shower or tub but requires presence of another person 4 = unable to use the shower to tub but table to bathe self independently with or without the use of devises at the sink, in chair or on commode 5 = unable to use the shower or tub but able to participate in bathe self in bed, at the sink or in bedside chair with assistance or supervision of another person 6 = unable to participate effectively in bathing and is bathed totally by another person 7 = completely independent 6 = modified independence 5 = supervision (subject = 100%) 4 = minimal assistance (subject = 75% of more) 3 = moderate assistance (subject = 50% or more) 2 = max assistance (25% or more) 1= total assistance 0 activity did not occur
Rating of questions MDS IRF – average function OASIS – typical ability MDS – most dependent Rating Instructions 0 = independent– no help provided 1 = supervision– oversight help only 2 = physical help limited to transfer only 3 = physical help in part of bathing activity 4 = total dependence 8 = activity did not occur
Wording of questions: Bathing IRF-PAI: “Bathing” OASIS: “Current ability to wash entire body safely, Excludes grooming (washing face, washing hands, and shampooing hair)” MDS: “How resident takes full-body bath/shower, sponge bath, and transfers in /out of tub/shower (excludes washing of back and hair)”
Tissue Type ratings differ • IRF 1 = epithelial tissue 2 = granulation tissue 3 = slough 4 = necrotic tissue • HH 0 = newly epithelialized 1 = fully granulating 2 = early/partial granulation 3 = not healing • SNF 1 = epithelial tissue 2 = granulation tissue 3 = slough 4 = necrotic tissue
Focus on all cause all disease • National Quality Forum & CMS require minimum number of patients in each measure (e.g. minimum denominator size) which is usually 25-30 • Implications for measures that are not all cause or disease specific
# Part A admissions for Top 15 Hospital DRGs by Facility annual volume of Part A admissions
Average volume Medicare Admissions per SNF for #1 Admitted diagnosis
Change in Decile Rank from Actual to Risk Adjusted SNF Rehospitalization