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VOLUME TO VALUE: CHALLENGES & OPPORTUNITIES

Update on the AOTA Quality Program

October 12, 2018

The Quality Team

Sharmila Sandhu, JD Director of Regulatory Affairs

Jennifer Bogenrief, JD Assistant Director of Regulatory Affairs

Jeremy Furniss, OTD OTR/L BCG Director of Quality

Volume to Value | Quality Team Presentation to the ALC

Agenda

• Incentives for Health Systems Today

• Countdown to new Value Based Programs

• Consider Future Incentives & the Response from OT

Volume to Value | Quality Team Presentation to the ALC

OT Services

⇡ staff ⇡ hours ⇡ productivity

Organization Reimbursement

⇡ Dollars

⇡ Audit Activity Incentives for Health Systems

• Hire more OT Practitioners • Maximize productivity • Focus on defensive

documentation to minimize negative audit findings

OT Services & Medicare Payment Today

Medicare is Making Changes

• An effort to change incentives for health systems

• We’ll count down changes in 4 practice areas

• These are the highlights, make sure to…

– Check out links for more info on aota.org

– Keep an eye out for new training modules

Volume to Value | Quality Team Presentation to the ALC

VBP Payment changes based

on Quality Measure performance

Medicare A Quality Programs

Value Based Purchasing

QRP Public Reporting of

Quality Measure performance

Quality Reporting Program

Volume to Value | Quality Team Presentation to the ALC

IMPACT Act

• Mandated changes in Post-Acute Care, including… – Domains using standardized (uniform) data elements – Implement quality measures from five quality measure domains

using data – Development and reporting of measures pertaining to

resource use, hospitalization, and discharge to the community

• CMS created standardized data elements that can be found at https://del.cms.gov

• Section GG is one of these areas

Volume to Value | Quality Team Presentation to the ALC

Section GG Self-Care Elements

• Eating

• Oral hygiene

• Toilet hygiene

• Shower/bathe self

• Upper body dressing

• Lower body dressing

• Putting on/taking off footwear

6: Independent 3: Partial/moderate assist 5: Setup or cleanup assist 2: Substantial/maximal assist 4: Supervision or touching assist 1: Dependent

Template & Education at www.aota.org/care Check out the link to the official CMS training!

Volume to Value | Quality Team Presentation to the ALC

Volume to Value | Quality Team Presentation to the ALC

#4 January 1, 2020

Volume to Value | Quality Team Presentation to the ALC

Home Health HH (Draft Rule)

Section GG

Yes

QRP Yes. Self-Care Measures are based on legacy data elements

VBP Demonstration (9 states)

Therapy Time

OT visits no longer contribute to payment as of Jan 1, 2020

#3 October 1, 2019

Volume to Value | Quality Team Presentation to the ALC

Inpatient Rehabilitation Facilities HH IRF

Section GG

Yes Yes. FIM™ is being replaced by GG. Used for Measures & Payment

QRP Yes. Self-Care Measures are based on legacy data elements

Yes. Self-Care & Mobility Measures based on GG

VBP Demonstration (9 states)

Not yet

Therapy Time

OT visits no longer contribute to payment as of Jan 1, 2020

Does not impact payment

#2 October 1, 2019

Volume to Value | Quality Team Presentation to the ALC

Skilled Nursing Facilities HH IRF SNF

Section GG

Yes Yes. FIM™ is being replaced by GG. Used for Measures & Payment

Yes. Used for Measures & Payment

QRP Yes. Self-Care Measures are based on legacy data elements

Yes. Self-Care & Mobility Measures based on GG

Yes. Self-Care & Mobility Measures based on GG

VBP Demonstration (9 states)

Not yet Yes. 1st Payment Adjustment 10/1/18

Therapy Time

OT visits no longer contribute to payment as of Jan 1, 2020

Does not impact payment

OT minutes no longer contribute to payment as of Oct 1, 2019

BEFORE WE GET TO #1…

Volume to Value | Quality Team Presentation to the ALC

Organization Reimbursement

⇡ Dollars

⇡ Consumers d/t ⇡ QRP Measures

⇡ VBP Measures

OT Services

staff hours

Incentives for Health Systems

• Maximize staff that have an impact on quality measures

• Minimize staff that have little or no impact on quality

• Focus on collaboration and documentation that identifies value

• Identify gaps and improve care using quality measures

Future of OT Services & Medicare Payment

Examples of QRP & VBP Measures

• Functional Outcome Measure: Change in Self-Care Score (based on Section GG)

• Percent of Residents Experiencing One or More Falls with Major Injury

• Percent of Patients or Residents with Pressure Ulcers that are New or Worsened

Volume to Value | Quality Team Presentation to the ALC

#1 January 1, 2019

Volume to Value | Quality Team Presentation to the ALC

Quality Payment Program (QPP)

• Medicare Part B Outpatient (not facility based… yet)

• In 2019, Best performers can earn +7% to 2021 payments. Worst performers can earn -7%.

• Low Volume Threshold determines eligibility

– 60 OT NPIs mandated to participate

– 4,400 OT NPIs eligible to opt-in

Volume to Value | Quality Team Presentation to the ALC

QPP Categories In 2019, OT will likely only be scored on 2 of the 4 categories:

Quality Report 6 measures

(1 outcome or high priority).

Scored based on performance.

Improvement Activities

Complete 90-days of quality

improvement using selected activities

Cost Compares the

cost of services to peers

Promoting Interoperability

Measures based on the use of certified EHR technology

Volume to Value | Quality Team Presentation to the ALC

Claims 1. N-0101 Falls: Screening, Risk

assessment, and POC 2. N-0421 BMI Screen & Plan 3. N-0419 Doc Meds in Record 4. N-0420 Pain Assess & f/u 5. N-2624 Functional Outcome 6. N-0028 Tobacco Use 7. N-0418 Depression Screen & f/u 8. Q-181 Elder Maltx screen & f/u

Registry/EHR 1. N-0422 FOTO Knees

2. N-0423 FOTO Hip

3. N-0424 FOTO Foot/Ankle

4. N-0425 FOTO Lumbar

5. N-0426 FOTO Shoulder

6. N-0427 FOTO Elbow, Wrist, Hand

7. N-0428 FOTO Gen Ortho

8. N-2152 Unhealthy Alcohol Use

9. 281 - Dementia: Cognitive Assmt

10. 282 - Dementia: Functional Status Assmt

11. 283 - Dementia: Associated Behavior/Psych

12. 286 - Dementia: Safety Concerns

QPP (MIPS) Quality Measures

Volume to Value | Quality Team Presentation to the ALC

Improvement Activities A few examples • Depression screening • Engagement of Patients, Family, and Caregivers in Developing a Plan of Care • Implementation of fall screening and assessment programs • Participation in Quality Improvement Initiatives • Practice Improvements that Engage Community Resources to Support

Patient Health Goals • Promote Use of Patient-Reported Outcome Tools • Tobacco use • Unhealthy alcohol use • Use of decision support and standardized treatment protocols

Volume to Value | Quality Team Presentation to the ALC

QPP.CMS.GOV

AOTA QUALITY PROGRAM

To maintain relevance…

OT practitioners must deliver high-quality services that

impact each client and

impact systems level quality measurement.

What is AOTA Doing?

• We support OTs who review, critique, and/or recommend quality measures for every program

• We develop clinical resources for practitioners www.aota.org/care | www.aota.org/profile

• We provide feedback directly to CMS

• We work with measure developers

• We are developing action oriented education

Volume to Value | Quality Team Presentation to the ALC

• PCPI Primary & Preventive Care TEP • PCPI Measure Advisory Committee • AAPM&R & PCPI Measure Development • NQF Neurology Committee • NQF Serious Mental Illness Action Team • NQF Adult Medicaid Group • NQF Medicaid Scorecard • NQF Cancer Standing Committee • NQF Clinician Workgroup • NQF Admissions & Readmissions

Workgroup

• NQF Post-Acute Care Workgroup • NQF Clinician Workgroup • NQF Membership Advisory Council • CMS MSK Non-spine Cost Measure Dev • CMS MSK Cost Measure Dev • CMS Psych Cost Measure Dev • CMS Neuro Cost Measure Dev • CMS Measure Development Plan TEP • CMS Unified PAC PPS TEP • CMS IMPACT TEP (multiple) • And more…

2018 External Quality Work

There are over 20 committees/groups that include OTs just this year!

Volume to Value | Quality Team Presentation to the ALC

Areas to Address in an OT Eval 1. Occupational Profile

Occupational Performance

1. ADLs

2. IADLs

3. Fall Prevention / Fear

4. Psychosocial Skills

5. Functional Cognition

6. Vision

Our Initial Focus is the OT Eval

Volume to Value | Quality Team Presentation to the ALC

Quality Measure Examples • Readmissions

• Change in Self-Care

• Fall with major injury

• Discharge to community

• Falls: Screening, Risk Assessment, and POC

• Functional Outcome

• Depression Screen & f/u

Areas to Address in an OT Eval 1. Occupational Profile

Occupational Performance

1. ADLs

2. IADLs

3. Fall Prevention / Fear

4. Psychosocial Skills

5. Functional Cognition

6. Vision

Our Initial Focus is the OT Eval

Volume to Value | Quality Team Presentation to the ALC

Quality Measure Examples • Readmissions

• Change in Self-Care

• Fall with major injury

• Discharge to community

• Falls: Screening, Risk Assessment, and POC

• Functional Outcome

• Depression Screen & f/u

Areas to Address in an OT Eval 1. Occupational Profile

Occupational Performance

1. ADLs

2. IADLs

3. Fall Prevention / Fear

4. Psychosocial Skills

5. Functional Cognition

6. Vision

Our Initial Focus is the OT Eval

Volume to Value | Quality Team Presentation to the ALC

Questions for Practitioners

• Can we answer: “How do I, as an OT practitioner, contribute to client and system outcomes?”

• Are we familiar with Medicare quality programs— VBP, QRP, QPP? How OT contributes?

• Are we comfortable with Section GG as a measure for self-care & mobility? Are we experts?

• Can we implement a quality improvement project?

Volume to Value | Quality Team Presentation to the ALC

Slide Deck

• Visit https://bit.ly/alc18q to download the PowerPoint and PDF versions of the slide deck

• The PowerPoint version has bonus slides that include an activity using Nursing Home Compare quality measures

• Feel free to edit and use the slides in your programs

Volume to Value | Quality Team Presentation to the ALC

quality@aota.org

Questions, Ideas, & Discussion

Bonus Slides

• These slides were put together for use with students in the classroom

• Keep an eye out for additional resources & education from AOTA

• SNF Measures are included. Measures in other settings will vary.

• Here’s a great presentation from PCPI on the PDSA process discussed in these slides

Volume to Value | Quality Team Presentation to the ALC

SNF QRP Measures Measure Data Status

Application of Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay) MDS Implemented

Percent of Patients or Residents with Pressure Ulcers that are New or Worsened MDS Implemented

Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function

MDS Implemented

Discharge to Community- Post Acute Care (PAC) Skilled Nursing Facility (SNF) Quality Reporting Program (QRP)

Claims Implemented

Potentially Preventable 30-Days Post-Discharge Readmission Measure for Skilled Nursing Facility (SNF) Quality Reporting Program (QRP)

Claims Implemented

Medicare Spending Per Beneficiary – Post-Acute Care (PAC) Skilled Nursing Facility Measure Claims Implemented

Volume to Value | Quality Team Presentation to the ALC

SNF QRP Measures: FY 2020 Claims Measure

Medicare Spending Per Beneficiary (MSPB)—Post Acute Care (PAC) Skilled Nursing Facility (SNF) Quality Reporting Program (QRP).

Discharge to Community Post Acute Care (PAC) Skilled Nursing Facility (SNF) Quality Reporting Program (QRP)

Potentially Preventable 30-Day Post-Discharge Readmission Measure for Skilled Nursing Facility (SNF) Quality Reporting Program (QRP).

• FY 2020 begins Oct 1, 2019

• This slide includes measures calculated with claims data

• The next slide includes measures calculated with data from the Minimum Data Set (MDS)

SNF QRP Measures: FY 2020 MDS

Measure

Percent of Residents or Patients With Pressure Ulcers That Are New or Worsened (Short Stay) (NQF #0678).

Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury.

Application of Percent of Residents Experiencing One or More Falls with Major Injury (Long Stay) (NQF #0674).

Application of Percent of Long-Term Care Hospital (LTCH) Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631).

Application of IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients (NQF #2634).

Application of IRF Functional Outcome Measure: Discharge Mobility Score for Medical Rehabilitation Patients (NQF #2636).

Application of the IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients (NQF #2633).

Application of IRF Functional Outcome Measure: Discharge Self-Care Score for Medical Rehabilitation Patients (NQF #2635).

Drug Regimen Review Conducted With Follow-Up for Identified Issues- Post Acute Care (PAC) Skilled Nursing Facility (SNF) Quality Reporting Program (QRP).

Activity

• Visit Nursing Home Compare

• Select a facility (in the area, from a fieldwork, etc.)

• Identify a quality measure for improvement

• Identify the ways OT can impact the measure, questions you would ask, & possible action steps

Volume to Value | Quality Team Presentation to the ALC

Visit: https://www.medicare.gov/nursinghomecompare/

Or search for “Nursing Home Compare”

Search for your SNF

here

“Stars” provide an overview meant for consumers

Click the name of your facility to get to the good stuff!

Each tabs is important. But, we are going to focus on

“Quality”

Each tabs is important. But, we are going to focus on

“Quality”

For SNF, there are 2 sets of measures—check out both!

Short-stay & Long-stay

Up to Date

• Click on current data collection period • These measures are often a few months old • New measures may not be published yet • The facility can pull current measures using

– Electronic Health Records and/or – CASPER reports (Available from a CMS portal)

Short Stay Measures

The performance of your facility is in this column.

Short Stay Measures

The average performance of your state is in this column.

Short Stay Measures

The national average performance is in this column.

Short Stay Measures

While most all of these measures relate to OT, some are directly connected!

Short Stay Measures

All of these measures are important. Measures that are worse than state or national will likely rise to the top of priorities!

Short Stay Measures

Your facility can identify the people in the measure using MDS software or CASPER report.

Short Stay Measures

• What questions might you ask for this measure? • Were the people with pressure ulcers that are new or worsened

referred to OT? – If so, what areas did the OT address in the evaluation & intervention? – If not, why not? Can this be changed?

• Identify ways in which OT may help the interdisciplinary team improve on the measure. – Is OT evaluating ADL and IADL performance for clients who are at risk

for pressure ulcers? (e.g., toileting for people with decreased independence in mobility)

Volume to Value | Quality Team Presentation to the ALC

HOW CAN WE USE THIS INFORMATION TO IMPLEMENT A PDSA CYCLE?

Volume to Value | Quality Team Presentation to the ALC

PDSA Cycle

Download a PDSA Worksheet from the Institue for Healthcare Improvement Plan

– State the objective or purpose – Make a prediction of what will happen and why – Develop a plan to test the change

• Who? What? When? Where?

– What data needs to be collected? – Generate a Good Idea

Volume to Value | Quality Team Presentation to the ALC

PDSA Cycle

Do – Test the change on a small scale (e.g., one patient,

one unit, one shift, one hour – “1:1:1 test”)

– Document what happened – problems and unexpected observations

– Begin data analysis

– Test on a SMALL scale!

Volume to Value | Quality Team Presentation to the ALC

PDSA Cycle

Study

– Complete data analysis

– Compare data to predictions

– Summarize learnings and think about meaning

– Don’t Forget to Study the results!

Volume to Value | Quality Team Presentation to the ALC

PDSA Cycle

Act

– Adopt, adapt, abandon the change based on results of the test

– Prepare plan for next test

– Adjust and Do Again

Volume to Value | Quality Team Presentation to the ALC

Compare Sites This process works the same way for most settings. See the sites below: • Home Health Compare

https://www.medicare.gov/homehealthcompare/search.html • Inpatient Rehabilitation Facility Compare

https://www.medicare.gov/inpatientrehabilitationfacilitycompare/ • Long Term Care Hospital Compare

https://www.medicare.gov/longtermcarehospitalcompare/ • Hospital Compare

https://www.medicare.gov/hospitalcompare/ • Physician Compare (Including OT in private practice)

https://www.medicare.gov/physiciancompare/

Volume to Value | Quality Team Presentation to the ALC