Hospice Quality Reporting Program updates were at the forefront of the FY 2022 Hospice Final Rule.
The Hospice Care Index and Visits in the Last Days of Life, both claims-based measures, will provide consumers with visibility into the quality of care that hospice organizations provide. Where does that leave hospice quality assessment and performance improvement (QAPI) programs?
Hospice QAPI programs are a hospice condition of participation and remain an active and vital part of daily activities for hospice organizations.
Per the regulation, QAPI programs should be designed to meet the specific needs of the hospice organization. With so many data points and options, hospice leaders must be laser-focused on these quality indicators at a higher level to guide their teams to improved quality of care.
1. On-Call Statistics
On-call statistics are meaningful to clinical and non-clinical leaders. While we expect on-call visits, looking at the frequency of those calls provides key insights into the quality of care of an organization. When an increase in on-call visits occurs, leaders should consider any current community-wide spread of illness, as well as the days and times of the calls.
Are they associated with a specific nurse or patient? If so, are we seeing changes in the patient’s plan reflecting their increased needs?
2. Live Discharges
Live discharges are vital to identifying quality issues that should be included in your QAPI program. Understanding live discharges and making them a meaningful part of your QAPI program is two-pronged.
Patients may move out of your service area, become ineligible for hospice services or be discharged for cause. Focusing on live discharges related to transfers to another hospice organization or revocations will help you know where to focus your efforts. Understanding why a patient chose to revoke their hospice benefit or transfer to another hospice is where you will find the information that should be measured and evaluated by the QAPI team.
3. Average Length of Stay
The average length of stay should be evaluated to identify patients who discharge during their first seven days of care or after 180 days of care.
Patients who discharge in the first week of hospice care may indicate that the patient or their legal representative did not understand the hospice benefit or were not satisfied with their hospice experience. Patients who are discharged after 180 days of care should be evaluated to identify trends that indicate that they have been discharged because of the risk associated with having patients on service longer than the expected six months.
Conversely, patients who are on service greater than 180 days should be monitored to ensure that they remain hospice eligible.
4. Pharmacy Expenses
Pharmacy expenses outside of the hospice benefit have long been a focus of the Office of Inspector General (OIG), the Centers for Medicare and Medicaid Services (CMS) and MedPac. The Office of Inspector General reports that there were $422.7 million in Part D total costs for prescriptions filled for hospice beneficiaries in their most recent audit.
To support compliance, include the Part D claims for your patients in your QAPI program. Part D payment details are included in the organization’s PEPPER report and should be reviewed each time a new report is available in the PEPPER Resource Portal.
5. Past Survey Reports
Hospice leaders should review past survey reports and include them in their QAPI program.
Site visitors and surveyors reference these reports in preparation for their visit and frequently look for the deficiency to have been repeated following its correction. Later this year, hospice organizations may be subject to new enforcement remedies, including civil monetary penalties, resulting from survey deficiencies.
Beyond having a compliant and meaningful QAPI program, leveraging survey history may help to protect your hard-earned revenue.
Hospice leaders should take a proactive approach, consistently analyzing these quality measures to ensure QAPI program success.
Axxess Hospice, a cloud-based hospice and palliative care software, includes HIPAA-compliant features built in for efficient reviews, as well as data reports available in real time.
