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PDGM: What About Therapy Presented by: Gina Mazza, BSN, RN Senior Vice President Kerry Termine, DPT Director of Coding QI October 15, 2018

PDGM: What About Therapy? Presented by: Gina Mazza, BSN, RN Senior Vice President Kerry Termine, DPT Director of Coding QI TODAY S OBJECTIVES Identify the case mix factors used in the PDGM related to therapy services. Discuss best practice recommendations for ensuring quality of care by including therapy services under PDGM. IT S A CHANGING WORLD! In a world of change there is no standing still! 1

PATIENT DRIVEN GROUPINGS MODEL (PDGM) GOALS Better align payment with costs Increase access to vulnerable patients associated with lower margins Address payment incentives in current system, i.e. eliminate impact of therapy volume on payment Place patients into clinically meaningful payment categories Effective January 1, 2020 Used with Permission: Abt Associates, Medicare Home Health Prospective Payment System: Case Mix Methodology Refinements. Overview of Home Health Grouping Model. November 18, 2016 HHS. CMS. Medicare and Medicaid Programs: CY 2019 Home Health Prospective Payment System Rate Update and Proposed CY 2020 Case Mix Adjustment Methodology Refinements; Home health Value Based Purchasing Model; and Home Health Quality Reporting Requirements. Final Rule. 30-DAY UNIT OF PAYMENT 30-day period = days 1-30 of a current 60-day episode where day 1 is the current 60-day episode s From Date. Second period is days 31 and above. CMS will calculate a proposed, national, standardized 30-day payment amount. Would propose the actual 30-day payment amount in the CY 2020 HH PPS proposed rule. Going forward will calculate payment amount by updating the preceding year by the HH payment update percentage. Nursing Therapy Ratio Revenue Impact Nursing Therapy Ratio Average Average Payment Payment per 60-60-day Episode day, PDGM Payment Change Percent Change 1st Quartile (Lowest 25% Nursing) $3,240.26 $2,919.00 -$321.26-9.91% 2nd Quartile $2,952.24 $2,928.58 -$23.67-0.80% 3rd Quartile $2,819.50 $3,001.58 $182.07 6.46% 4th Quartile (Top 25% Nursing) $2,605.20 $3,048.29 $443.08 17.01% Fazzi sbi Analysis 2

WHAT ABOUT VBP AND COPS? The individualized plan of care must specify the care and services necessary to meet the patient-specific needs as identified in the comprehensive assessment, including identification of the responsible discipline(s), and the measurable outcomes that the HHA anticipates will occur as a result of implementing and coordinating the plan of care. The individualized plan of care must also specify the patient and caregiver education and training... PLAN OF CARE REQUIREMENTS i. Pertinent diagnosis ii. Mental, psychosocial and cognitive status iii. Services, supplies and equipment required iv. Frequency and duration of visits v. Prognosis vi. Rehabilitation potential vii. Functional limitations viii. Activities permitted ix. Nutritional requirements x. All medications and treatments xi. Safety measures to protect against injury xii. A description of the risk for ER visits and hospitalization re-admission, and all interventions that address underlying risks xiii. Patient/caregiver education and training to facilitate discharge xiv. Patient-specific interventions and education; measurable outcomes and goals identified by the HHA and patient xv. Information related to advanced directives xvi. Any additional items the physician or HHA may choose COORDINATION OF CARE 1. Assure communication with all physicians involved in the plan of care. 2. Integrate orders from all physicians to assure coordination. 3. Integrate all services to assure the identification of patient needs patient safety, treatment effectiveness and the coordination of care provided by all disciplines. HH CoP Final Rule 3

COORDINATION OF CARE, CONT. 4. Coordinate care delivery to meet the patient s needs, and involve the patient, representative (if any), and caregiver(s), as appropriate, in the coordination of care activities. 5. Ensure that each patient, and his or her caregiver(s) where applicable, receive ongoing education and training provided by the HHA, as appropriate, regarding the care and services identified in the plan of care. The HHA must provide training, as necessary, to ensure a timely discharge. Home Health CoP Final Rule PDGM CASE MIX WEIGHT STRUCTURE Admission Source and Timing Clinical Grouping Comorbidity Adjustment OASIS Items-Functional Level An episode is grouped into one (and only one) subcategory under each category. An episode s combination of subcategories groups the episode into one of 432 different payment groups. Patient Driven Groupings Model Admission Source and Timing Community Early Community Late Institutional Early Institutional Late Functional Level Low Medium High Clinical Group MMTA Surgical Aftercare Neuro Rehab MMTA Cardiac/Circulatory Wounds MMTA Endocrine Complex Nursing MMTA GI/GU Interventions MMTA Infectious Disease/ MS Rehab Neoplasms/Blood Forming Behavioral Health Disease MMTA Respiratory MMTA Other Comorbidity None Low High = HHRG 432 4

CLINICAL GROUPINGS Each 30-day period of care will be assigned to one of twelve groups based on the reported principal diagnosis. Diagnosis code must support the need for HH services. Secondary diagnosis codes would then be used to case-mix adjust the period further through additional elements of the model, such as the comorbidity adjustment. PDGM CLINICAL GROUPS Clinical Group Musculoskeletal Rehabilitation Neuro/Stroke Rehabilitation Wounds Post Op Wound Aftercare and Skin/Non Surgical Wound Care Behavioral Health Care Complex Nursing Interventions Primary Reason for HH Encounter: Therapy (PT/OT/SLP) for a musculoskeletal condition Therapy (PT/OT/SLP) for a neurological condition or stroke Assessment, treatment and evaluation of a surgical wound(s); assessment, treatment and evaluation of nonsurgical wounds, ulcers, burns and other lesions Assessment, treatment and evaluation of psychiatric conditions Assessment, treatment and evaluation of complex medical and surgical conditions including IV, TPN, enteral nutrition, ventilator, and ostomies PDGM CLINICAL GROUPS, CONTINUED Clinical Group MMTA Surgical Aftercare MMTA Cardiac/Circulatory MMTA Endocrine MMTA GI/GU MMTA Infectious Disease/Neoplasms/Blood forming Diseases MMTA Respiratory MMTA Other Primary Reason for HH Encounter: Assessment, evaluation, teaching, and medication management for surgical aftercare Assessment, evaluation, teaching, and medication management for cardiac or other circulatory related conditions Assessment, evaluation, teaching, and medication management for endocrine related conditions Assessment, evaluation, teaching, and medication management for gastrointestinal or genitourinary related conditions Assessment, evaluation, teaching and medication management for conditions related to infectious diseases, neoplasms, and blood forming diseases Assessment, evaluation, teaching and medication management for respiratory related conditions Assessment, evaluation, teaching, and medication management for a variety of medical and surgical conditions not classified in one of the previously listed groups 5

IMPACT RATIO BY CLINICAL GROUP 0.85 1.06 0.99 1.09 1.09 0.98 1.01 0.97 0.96 0.97 0.93 1.25 FUNCTIONAL IMPAIRMENT Functional status allows for higher payment for higher service needs. Functional scores result in 3 levels: low, medium, high Functional levels per clinical group Functional scores and levels will be updated for 2020 IMPACT RATIO FOR FUNCTIONAL LEVELS 1.06 0.95 0.99 Low Medium High 6

FUNCTIONAL ITEMS Current HH PPS PDGM M1800: Grooming M1810: Dressing upper body M1810: Dressing upper body M1820: Dressing lower body M1820: Dressing lower body M1830: Bathing M1830: Bathing M1840: Toileting M1840: Toileting M1850: Transferring M1850: Transferring M1860: Ambulation & locomotion M1860: Ambulation & locomotion M1033: Risk of Hospitalization OASIS BEST PRACTICES Assessment should include observation of functional activities. Encourage clinicians to consider the most dependent score first and work towards the more independent scores. Reinforce with clinicians: - Functional OASIS scores should be selected based on the patient s ABILITY to SAFELY perform the task. - Functional OASIS scores should not be scored on the availability of a caregiver. COMORBIDITIES No Adjustment: No comorbidity diagnosis that falls into a comorbidity adjustment subgroup. Low Comorbidity Adjustment: A comorbidity diagnosis that falls into one comorbidity adjustment subgroup. High Comorbidity Adjustment: Two or more diagnosis that fall within the same comorbidity subgroup interaction. 7

IMPACT RATIO FOR COMORBIDITY 1.15 0.97 1.02 No Adjustment Single Comorbidity Interaction KEY ELEMENTS OF CARE DELIVERY 1. OASIS Assessment OASIS D Training OASIS/Coding Competency Process Plan for More Changes 2. Coding Expertise Essential Competency Maintain experts and/or outsource 3. Effective Care Management Implement/maintain care management processes IDT approach helps identify risks, goals and the plan Use Care Manager/s role Bridges care delivery with QAPI Under Value Based Purchasing, agencies will still be measured on the quality of care provided. - Therapy services may be necessary to manage outcomes related to improvement of patient self-care and mobility during a quality episode. HHCAHPS performance measures will still involve patient s/caregiver s evaluation of safety needs being addressed Conditions of Participation require agencies to provide comprehensive care to address all of the patient s needs 24 KEYS TO QUALITY 8

COMPETENCY ASSESSMENT STRATEGIES 1. Joint Visits Clinical Manager or Coworker Standardized Feedback Forms 2. IDT Meetings SBAR-G 3. Audit of Clinician Documentation Are OASIS scores supported? Is the source of patient problem s tied to specific diagnoses? BEST PRACTICE RECOMMENDATIONS Ensure OASIS Assessment Competency Create a Culture of Treating the Whole Patient Develop Strategies for Supporting Therapy Services Ensure Effective Care Management Practices CONTROLLING YOUR FUTURE The best way to predict the future is to create it. - Peter Drucker 9

Fazzi Associates, Inc. (800) 379-0361 www.fazzi.com gmazza@fazzi.com ktermine@fazzi.com 10