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IRF Incidence of Adverse and Temporary Harm on OIG 2015 Plan

Written by: Darlene D'Altorio-Jones (1959-2015) on Thursday, January 1, 2015 Posted in: Inpatient Rehab

Is the 2015 OIG Plan for IRF Actionable?

The 2015 Work Plan lists one item to be reviewed for IRF’s in 2015, but since that item is not a measure specifically reported, how will this data be discovered and tracked in 2015? This is what OIG has stated for the IRF 2015 Plan:

“We will estimate the national incidence of adverse and temporary harm events for Medicare beneficiaries receiving postacute care in inpatient rehabilitation facilities (IRF).”

Previous years’ work plans paid special attention to the requirements specific to an IRF operation.  For example, the 2013 Plan included more traditional IRF monitors such as late transmission of data assessments and appropriateness for admission to an IRF based on 2010 guidelines, as well as examining the level of group treatment in IRF’s; this most likely led to the future tracking of treatment type in the next fiscal year.

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Per the OIG 2015 Work Plan there is a continuation of the 2014 plan, which was a heads-up notification that OIG would be looking at Adverse Events in Post Acute Care not only in IRF but in SNF and LTCH environments too.

This is their oversight plan for 2015:

“We will estimate the national incidence of adverse and temporary harm events for Medicare beneficiaries receiving postacute care in inpatient rehabilitation facilities (IRF). We will also identify factors contributing to these events, determine the extent to which the events were preventable, and estimate the associated costs to Medicare. IRFs are inpatient facilities that provide intensive rehabilitation therapy to patients recovering from illness, injury, or surgery, typically consisting of at least 3 hours of therapy per day. Upon discharge from the hospital, IRF residents often require extensive services to improve functioning before returning home. IRFs provide 11 percent of postacute facility care and have experienced rapid growth over the last decade. IRF care accounted for $7 billion in Medicare expenditures in 2011. (OEI; 06-14-00110; expected issue date: FY 2015).”

OIG recognizes that ‘Adverse and Temporary Harm’ occurs in the practice of medicine. In addition, adverse events are not always tracked and/or analyzed to prevent recurrence of an incident. With patient safety taking a front seat in the ACA, and with the addition of outcomes monitoring in pay for performance driven systems, OIG has studied and published the cost not only to human life but in health care dollars and that affect Medicare Beneficiaries.

When patients are at higher risk of adverse events, hospitals are also at higher risk and could be cited for deficiencies and terminated from Medicare participation according to the OIG. These are  compelling reasons to bolster hospital reporting systems and to ensure they are integrated into the hospital’s Quality Assessment and Performance Improvement (QAPI) plans. As Condition of Participation (CoP) in Medicare, CMS has mandated adverse event tracking.  However, the CMS State Operations Manual(s) contains no guidance to state survey agencies regarding assessment of hospital compliance with federal requirements to track and monitor events; therefore, it is unclear how surveyors are to assess hospitals’ compliance.

The CMS hospital Condition of Participation for QAPI at 42 CFR 482.21(a)(2) requires hospitals to track adverse patient events. Further, hospitals are obliged to use the data to monitor the effectiveness and safety of services (42 CFR 482.21(b), analyze the causes of adverse patient events, and implement actions and mechanisms to prevent recurrence (42 CFR 482.21(c)(2).

If you presently believe you are lacking good tools for tracking and performing adverse event analyses, OIG recommends ‘AHRQ’s Common Formats’ that provide a harm scale for identifying and focusing on serious adverse events that may be preventable. The AHRQ harm scale standardizes evaluation of level of harm across different event types. These formats are free and publicly available. State surveyors are increasingly aware of their content as their use is widespread and they work well with Federal Reporting Systems when required.

AHRQ states, “The Common Formats have been implemented at hospitals and into patient safety and quality reporting software systems.” The Common Formats (versions 1.1 and 1.2), including sample aggregate reports, technical specifications, and other supporting materials are available at the above link.

If you believe you have room for improvement in your QAPI processes and in particular recognizing, recording and improving upon areas that lead to Adverse and Harmful Events; these links are specifically for you.  It’s better you take action than having an OIG over the shoulder review of processes not quite leading to improved performance and patient safety at your facility.