Written by Lisa Selman-Holman, VP of Education & Quality, and Michelle Horner, Manager of Post-Acute Education
Accurate assessment is the cornerstone for providing patient-centered care in all settings. In home health, we assess and track the functional status of patients to ensure accurate reimbursement, provide quality measure tracking and individualized plans of care. The Centers for Medicare and Medicaid Services (CMS) tracks and analyzes the data we collect and makes changes to programs accordingly. Currently, home health agencies utilize OASIS items from section G, the M1800s, to calculate reimbursement, Star ratings, and Value-Based Purchasing.
Medicare is planning a significant shift from using the M1800 (Section G) items to the GG items for quality outcome measures. Effective January 1, 2025, the GG items will replace the G items (M1800s) in the Quality Reporting Program (QRP) and Value-Based Purchasing (VBP). In VBP, the Total Normalized Composite (TNC) scores for self-care and mobility will be replaced by the Discharge Function Score.
Many of the recent changes we have seen with OASIS-E and the QRP programs have been due to the requirements for standardized data in post-acute care contained within The Improving Medicare Post-Acute Care Transformation Act of 2014 (the IMPACT Act). Using the GG items for the purposes of outcomes instead of the M1800s is likely the first step in the future omission of the M1800 functional items from the OASIS. All of the post-acute settings will be using the GG items for QRP and VBP by 2025. Effective Oct 1, 2023, CMS replaced the Skilled Nursing Facility (SNF) legacy functional items with the GG items, as the primary means of assessing and tracking patient’s functional status throughout their SNF stay. Changes in the home health arena tend to lag approximately two years behind SNFs when it comes to adopting new Medicare guidelines. For example, home health agencies were roughly two years behind SNFs in transitioning to new payment systems and new standardized assessment items. This is one of many steps towards compliance with the IMPACT Act.
It is crucial for home health agencies to ensure compliance and accuracy in the scoring of the GG items as they may not only be the source of outcome information, but also payment information in the next two years. Understanding the importance of GG items for accurate assessment and potential reimbursement is vital for providing high-quality care and avoiding potential compliance issues.
One of the barriers to improving the accuracy of scoring on the GG items has been that some healthcare professionals may mistakenly believe that the responses to the GG items need to “match” the responses to the functional M1800 items, leading to unnecessary confusion and potential errors in documentation. Automated systems and/or scrubbers might raise warnings based on perceived discrepancies. It is crucial for healthcare providers to thoroughly understand the guidance surrounding GG items to avoid such pitfalls and ensure accurate and compliant assessments. The G items and GG items vary greatly in guidance for completion, as well as what is included and excluded in the scoring.
Lastly, CMS has reported that home health agencies are responding with too many ‘activity not assessed’ (ANA) codes (07, 09, 10, 88 and the dash). CMS has been imputing those ANA codes to 01-dependent, but will, in the future, impute those to a score based on the patient characteristics reported elsewhere in the assessment. A reliance on ANA codes when not appropriate, will result in skewed results that likely will be negative for the outcomes.
By embracing the standardized GG items, home health professionals can improve accuracy in their responses, identify levels of function, work to improve that function, and indicate true outcomes. The GG items are much more efficient in identifying variances in function, and the guidance is more specific than the hodge-podge of guidance that has been provided with the M1800s over the years.
The Final Rule indicates that the implementation of the new Discharge Function Score will be January 1, 2025, and the industry’s baseline year is 2023. This means home health agencies should use 2024 to ramp up their accuracy of responding to the GG items to improve on their own scores and achieve better outcomes than their competitors.
Staff education and quality improvement processes should include concentration on the official CMS guidance and promoting of accurate responses, with minimal use of ANA responses. CMS will not just compare the response provided at SOC or ROC to DC as they do now but will compare the response at discharge to what they have imputed the outcome should be for that patient.
The transition from G-section items to GG items in Medicare’s patient assessment framework represents a crucial step toward improved accuracy and standardization. Understanding the significance of GG items, navigating challenges, and staying updated on Medicare guidance will empower home health professionals to effectively utilize GG items, ultimately leading to improved patient outcomes.