I am so proud of our last Weatherbee blog post (here) written by Dr. Suzanne Karefa-Johnson. I love how she elegantly reframed the physician narrative requirements. It resonated so completely with what I have always believed about hospice regulations - they are inherently good, they serve a purpose, they are worth the trouble because, ultimately, they protect patients and/or lead to better patient care.
It is because of my belief in the importance of hospice regulations that I am so crazed right now! For the past several weeks, my colleague Melanie Merriman and I have been feverishly (well, maybe not feverishly) working on an implementation guide for the Hospice Item Set (HIS) to help hospices with the operational challenges of meeting the July 1st compliance deadline. I believe in the Hospice Quality Reporting Program (HQRP),and I understand the point and importance of the HIS. In this post I want to talk about one part of the HIS that makes absolutely no sense to me: the completion deadlines.
There are specific deadlines that pertain to the HIS that we have categorized as submission deadlines, quality measure deadlines and completion deadlines.
The submission deadlines require that the HIS Admission Record is submitted to CMS no later than 30 days after the patient's admission date and the HIS Discharge Record is submitted no later than 30 days after the patient's discharge date. No problem here. The timeframe is reasonable, it makes sense.
The quality measure deadlines are the required timeframes for completing screenings, assessments, and care processes related to the quality measures. No problem here either. These timeframes are prescribed by the quality measures themselves, which have been tested for validity and reliability. Also, they are consistent 1) with good clinical practice; and 2) with what hospices are required to do anyway, for the most part, by the initial and comprehensive assessment conditions of participation.
So that leaves the completion deadlines (shoot me now). These deadlines require that the HIS Admission Record be completed no later than 14 days after the patient's admission date and that the HIS Discharge Record be completed by no later than 7 days after the patient's discharge date. So here are my questions which I am asking politely and respectfully:
- Why are there completion deadlines at all? And why are they different for the admission versus the discharge HIS?
- What does it matter when they are completed, as long as they are submitted timely?
- What purpose do the completion deadlines serve?
- Who do they help?
- Who cares about this, and why?
- Has anyone thought about the logistical nightmare this creates for hospices? If anyone has, are there some kind of tips to help hospices comply and minimize the time and effort this requires?
Melanie and I have racked our brains trying to figure out why the completion deadlines are part of the HIS. We have also racked our brains trying to figure out, from an operational perspective, what hospices will need to do to keep track of these completion deadlines and meet them. Perhaps hospices with an EMR vendor will have an easier time if the HIS records are auto-abstracted. But nevertheless, someone must attest to the completion of the HIS records and the date the completion attestation is signed must be within the required timeframes. So someone will need to track all admission dates, calculate plus 14 days and make sure the HIS Admission Record is completed by that date. Then that same someone (or another someone) will need to track all discharge dates and calculate plus 7 days and make certain all HIS Discharges are completed within that deadline. See the problem? Melanie and I spent hours devising an Excel spreadsheet tracking mechanism, to help hospices know when to pull each patient's medical record for HIS abstraction. We think it will make the process work, but it will still be enormously complicated since every patient has a unique admission and discharge date.
So that is my rant. One of my favorite nuns in high school used to chide me for getting on my soapbox and sometimes even trying to start revolutions when I perceived things were wrong. I think the completion deadlines are wrong and I am sorry to say, Sr. Colette (RIP), it brings out all my "we have to fight this" tendencies.
All I really want/need are answers for the questions I asked above. If I could make sense of these completion deadline requirements, as I have been able to do for the past twenty years with every hospice regulatory requirement I have come across, I will be quiet. I will even, as my colleague Dr. Karefa-Johnson did with the physician narrative, try to reframe the requirements into something hospices will embrace.
Until then, however, I suggest folks write to the HQRP help desk (HospiceQualityQuestions@cms.hhs.gov) and ask some of the questions I have raised. Perhaps this ship has already sailed, but if there is any chance of eliminating these completion deadlines, it will make compliance with the HIS so much easier and that is well worth the shot.
PS. If anyone has any thoughts about why the completion deadlines are necessary please post to the comments or send me an email. I am dying to know.
PPS. We are getting closer to completing The Hospice Item Set: A Step-by-Step Implementation Guide. If you want to be alerted when it is published and receive an order form, send an email to firstname.lastname@example.org with "Interested in the manual" in the subject line.
Posted by Heather P. Wilson, Ph.D. CEO, Weatherbee Resources