Many had the opportunity to call in and comment during the CMS Open Door meeting for establishing a quality reporting program for LTACHs, IRFs and Hospice providers. And you may be one of the many who repeatedly hit #1, and never had your comments heard. This technical impairment was unfortunate, given the importance of this issue to the remaining members of the CMS care provider continuum, yet to be saddled with quality reporting requirements. The Affordable Care Act has mandated quality measures to be reported by the year 2014, or be penalized with reduced Medicare payment.
These are interesting times for post acute care providers. We are on course toward a common assessment and classification system, which will help CMS justify the expense differences in providing post acute care given the different provider types. We need to consider why IRFs, LTACHs and Hospice providers are singled out and now linked by this legislation. This should not imply there are, or should be, common quality measures for these venues. These quality measures will eventually end up on CMS’ Healthcare Compare website, providing a cursory ranking of providers for public scrutiny.
Second, we should not assume these venues provide the same care effect because we classify patients with a common assessment instrument. Quality must be defined and measured specific to the expectation of each venue. Perhaps asking the question, “What is the guarantee of care provided?” is a logical place to start defining quality. If there is a difference in care outcomes, should a common outcome measure be attempted? Are the common care processes such that a common process measure may be applied in each?
Finally, what (whose) expectations should define quality? Provider, payor or patient may have differing expectations and the degree to which those are met. CMS offers no definition; instead, during the call probing questions were posed:
CMS: “What are you currently doing?”
Participants: “We have measures, outcome – process – satisfaction – functional independence – performance – errors – adverse events …
CMS: “Are they scientifically validated?”
Participant: “Sure everyone uses them.”
CMS: “How do you use measures to improve care and has it worked?”
Participant: (No Response)
From this vantage point, we launch the initiative to define quality for post acute care. Finding common ground and common expectations will be the challenge.