Home Health & Hospice Week

MedPAC model riddled with problems, industry reps say.

You'd better brush up on your OASIS accuracy because your Medicare reimbursement could ride on it even more.

Medicare would base home health agency pay for performance payment rates on 20 OASIS indicators, if the Medicare Payment Advisory Commission gets its way. That's one of the P4P recommendations MedPAC is considering for its June report to Congress on the matter, according to the Commission's January 10 meeting.

HHAs would receive a quality score based on aggregating those 20 OASIS measures, which include toileting, ambulating and managing oral medications, notes the American Association for Homecare.

MedPAC staffer Sharon Cheng proposed setting a reward pool for the top 20 percent of agencies and a penalty pool for the bottom 20 percent. The Commis-sion could also recommend incentive payments for agencies that improve the most.

Dilemma: MedPAC would have to decide whether to recommend setting the reward and penalty thresholds ahead of time based on historical data so agencies would know what they would be shooting for. Otherwise agencies would find out the thresholds well after the time period because the 20 percent lines would be calculated after claims had processed.

Smaller HHAs could have a tough time being measured under this system, Cheng acknowledged. To combat having a few patients skew an agency's data, MedPAC is considering recommending: • "confidence intervals" that would give agencies a range instead of a hard and fast outcome score, based on statistical significance.

• aggregating data over two years.

• allowing small agencies to form voluntary associations with other similarly situated providers to pool their outcome data. P4P Proposal Hurts Small Providers Industry representatives greeted the proposed P4P structure with dismay. "The model P4P system displayed by MedPAC staff fails on a number of fronts to meet the P4P principles that the National Association for Home Care & Hospice and other organizations in the home care community have established," NAHC blasts.

The proposal relies solely on OASIS data without any consideration of process measures. "Up until this meeting, it had been NAHC's impression that MedPAC recognized the serious problems attendant to relying simply on OASIS outcomes data," the trade group tells members in its newsletter.

"There are real issues about using OASIS outcome measures in a rewards and punishments context," warns Bob Wardwell with the Visiting Nurse Associations of America. There are no "good answers" yet to a number of disturbing questions about OASIS measures, says Wardwell, a former top Centers for Medicare & Medicaid Services official.

Confidence in the smaller number of measures chosen for CMS' proposed P4P demonstration project is hard enough, notes consultant Judy Adams with Charlotte, NC-based LarsonAllen. "Adding more outcomes under the MedPAC proposal is not reasonable or practical," Adams tells Eli.

And gaming [...]