NQF

Version Number: 8.7
Meeting Date: December 10, 2018

Measure Applications Partnership
PAC/LTC Workgroup Discussion Guide

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Agenda

Agenda Synopsis

Time Session
December 10, 2018  
8:30 AM   Breakfast
9:00 AM   Welcome, Introductions, Disclosures of Interest, and Review of Meeting Objectives
9:15 AM   CMS Opening Remarks
9:30 AM   Overview of Pre-Rulemaking Approach
9:50 AM   Overview of IMPACT Act Programs
10:30 AM   Opportunity for Public Comment on Transfer of Health Information to Provider—Post-Acute Care
10:45 AM   Pre-Rulemaking Input on Measures Under Consideration for IMPACT Act: Transfer of Health Information to Provider—Post-Acute Care
11:30 AM   Break
11:45 AM   Opportunity for Public Comment on Transfer of Health Information to Patient—Post-Acute Care
12:00 PM   Pre-Rulemaking Input on Measures Under Consideration for IMPACT Act: Transfer of Health Information to Patient—Post-Acute Care
12:30 PM   Lunch
1:00 PM   Hospice Quality Reporting Program (HQRP)
1:50 PM   Promoting Alignment in Measurement of PAC/LTC Care
2:15 PM   Opportunity for Public Comment
2:25 PM   Summary of Day and Next Steps
2:30 PM   Adjourn


Full Agenda

December 10, 2018  
8:30 AM   Breakfast
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9:00 AM   Welcome, Introductions, Disclosures of Interest, and Review of Meeting Objectives
Gerri Lamb, Workgroup Co-Chair
Paul Mulhausen, Workgroup Co-Chair
Erin O’Rourke, Senior Director, NQF
Sam Stolpe, Senior Director, NQF
Elisa Munthali, Senior Vice President, Quality Measurement, NQF


9:15 AM   CMS Opening Remarks
Michelle Schreiber, QMVIG Group Director, CMS


9:30 AM   Overview of Pre-Rulemaking Approach
Shaconna Gorham
  • MAP uses a three step approach
    • Provide program overview
    • Review current measures
    • Evaluate Measures Under Consideration (MUC) for what they would add to the program measure set
  • Review decision categories
  • Review voting procedures


9:50 AM   Overview of IMPACT Act Programs
  • Overview of HH QRP
  • Overview of IRF QRP
  • Overview of LTCH QRP
  • Overview of SNF QRP


10:30 AM   Opportunity for Public Comment on Transfer of Health Information to Provider—Post-Acute Care
10:45 AM   Pre-Rulemaking Input on Measures Under Consideration for IMPACT Act: Transfer of Health Information to Provider—Post-Acute Care
Measures under consideration:
  1. Transfer of Health Information to Provider—Post-Acute Care (MUC ID: MUC2018-131) (Program: HH QRP)
    • Description: The purpose of this measure is to assess for and report on the timely transfer of health information when a patient is discharged from their current setting of care. For this measure, the timely transfer of health information specifically assesses for the transfer of the patient’s current reconciled medication list. This process measure calculates the proportion of patient/resident stays or quality episodes with a discharge/transfer assessment indicating that a current reconciled medication list was provided to the subsequent provider at the time of discharge/transfer. (Measure Specifications)
    • Public comments received: 7
    • Preliminary analysis summary (Full Preliminary Analysis)
      • Contribution to program measure set:This measure could help improve the transfer of information about a patient’s medication, an important aspect of care transitions. Better care transitions could improve patient outcomes, reduce complications, and lessen the risk of hospital admissions or readmissions.
      • Impact on quality of care for patients:This measure would meet an IMPACT Act requirement, address PAC/LTC core concepts not currently included in the program measure set, and promote alignment across programs.
    • Preliminary analysis result: Conditional Support Pending NQF Endorsement


  2. Transfer of Health Information to Provider—Post-Acute Care (MUC ID: MUC2018-132) (Program: IRF QRP)
    • Description: The purpose of this measure is to assess for and report on the timely transfer of health information when a patient is discharged from their current setting of care. For this measure, the timely transfer of health information specifically assesses for the transfer of the patient’s current reconciled medication list. This process measure calculates the proportion of patient/resident stays or quality episodes with a discharge/transfer assessment indicating that a current reconciled medication list was provided to the subsequent provider at the time of discharge/transfer. (Measure Specifications)
    • Public comments received: 7
    • Preliminary analysis summary (Full Preliminary Analysis)
      • Contribution to program measure set:This measure could help improve the transfer of information about a patient’s medication elements, an important aspect of care transitions. Better care transitions could improve patient outcomes, reduce complications, and lessen the risk of hospital admissions or readmissions.
      • Impact on quality of care for patients:This measure would meet an IMPACT Act requirement, address PAC/LTC core concepts not currently included in the program measure set, and promote alignment across programs.
    • Preliminary analysis result: Conditional support pending NQF endorsement


  3. Transfer of Health Information to Provider—Post-Acute Care (MUC ID: MUC2018-133) (Program: LTCH QRP)
    • Description: The purpose of this measure is to assess for and report on the timely transfer of health information when a patient is discharged from their current setting of care. For this measure, the timely transfer of health information specifically assesses for the transfer of the patient’s current reconciled medication list. This process measure calculates the proportion of patient/resident stays or quality episodes with a discharge/transfer assessment indicating that a current reconciled medication list was provided to the subsequent provider at the time of discharge/transfer. (Measure Specifications)
    • Public comments received: 5
    • Preliminary analysis summary (Full Preliminary Analysis)
      • Contribution to program measure set:This measure could help improve the transfer of information about a patient’s medication elements, an important aspect of care transitions. Better care transitions could improve patient outcomes, reduce complications, and lessen the risk of hospital admissions or readmissions.
      • Impact on quality of care for patients:This measure would meet an IMPACT Act requirement, address PAC/LTC core concepts not currently included in the program measure set, and promote alignment across programs.
    • Preliminary analysis result: Conditional support pending NQF endorsement


  4. Transfer of Health Information to Provider—Post-Acute Care (MUC ID: MUC2018-136) (Program: SNF QRP)
    • Description: The purpose of this measure is to assess for and report on the timely transfer of health information when a patient is discharged from their current setting of care. For this measure, the timely transfer of health information specifically assesses for the transfer of the patient’s current reconciled medication list. This process measure calculates the proportion of patient/resident stays or quality episodes with a discharge/transfer assessment indicating that a current reconciled medication list was provided to the subsequent provider at the time of discharge/transfer. (Measure Specifications)
    • Public comments received: 4
    • Preliminary analysis summary (Full Preliminary Analysis)
      • Contribution to program measure set:This measure could help improve the transfer of information about a patient’s medication elements, an important aspect of care transitions. Better care transitions could improve patient outcomes, reduce complications, and lessen the risk of hospital admissions or readmissions.
      • Impact on quality of care for patients:This measure would meet an IMPACT Act requirement, address PAC/LTC core concepts not currently included in the program measure set, and promote alignment across programs.
    • Preliminary analysis result: Conditional support pending NQF endorsement


11:30 AM   Break
11:45 AM   Opportunity for Public Comment on Transfer of Health Information to Patient—Post-Acute Care
12:00 PM   Pre-Rulemaking Input on Measures Under Consideration for IMPACT Act: Transfer of Health Information to Patient—Post-Acute Care
Measures under consideration:
  1. Transfer of Health Information to Patient—Post-Acute Care (MUC ID: MUC2018-135) (Program: HH QRP)
    • Description: The purpose of this measure is to assess for and report on the timely transfer of health information when a patient is discharged from their current setting of care. For this measure, the timely transfer of health information specifically assesses for the transfer of the patient’s current reconciled medication list. This process measure calculates the proportion of patient/resident stays or quality episodes with a discharge/transfer assessment indicating that a current reconciled medication list was provided to the patient, family and/or caregiver at the time of discharge/transfer. (Measure Specifications)
    • Public comments received: 6
    • Preliminary analysis summary (Full Preliminary Analysis)
      • Contribution to program measure set:This measure could help improve the transfer of information about a patient’s medication elements, an important aspect of care transitions. Better care transitions could improve patient outcomes, reduce complications, and lessen the risk of hospital admissions or readmissions.
      • Impact on quality of care for patients:This measure would meet an IMPACT Act requirement, address PAC/LTC core concepts not currently included in the program measure set, and promote alignment across programs.
    • Preliminary analysis result: Conditional Support Pending NQF Endorsement


  2. Transfer of Health Information to Patient—Post-Acute Care (MUC ID: MUC2018-138) (Program: SNF QRP)
    • Description: The purpose of this measure is to assess for and report on the timely transfer of health information when a patient is discharged from their current setting of care. For this measure, the timely transfer of health information specifically assesses for the transfer of the patient’s current reconciled medication list. This process measure calculates the proportion of patient/resident stays or quality episodes with a discharge/transfer assessment indicating that a current reconciled medication list was provided to the patient, family or caregiver at the time of discharge/transfer. (Measure Specifications)
    • Public comments received: 6
    • Preliminary analysis summary (Full Preliminary Analysis)
      • Contribution to program measure set:This measure could help improve the transfer of information about a patient’s medication elements, an important aspect of care transitions. Better care transitions could improve patient outcomes, reduce complications, and lessen the risk of hospital admissions or readmissions.
      • Impact on quality of care for patients:This measure would meet an IMPACT Act requirement, address PAC/LTC core concepts not currently included in the program measure set, and promote alignment across programs.
    • Preliminary analysis result: Conditional support pending NQF endorsement


  3. Transfer of Health Information to Patient—Post-Acute Care (MUC ID: MUC2018-139) (Program: IRF QRP)
    • Description: The purpose of this measure is to assess for and report on the timely transfer of health information when a patient is discharged from their current setting of care. For this measure, the timely transfer of health information specifically assesses for the transfer of the patient’s current reconciled medication list. This process measure calculates the proportion of patient/resident stays or quality episodes with a discharge/transfer assessment indicating that a current reconciled medication list was provided to the patient, family, or caregiver at the time of discharge/transfer. (Measure Specifications)
    • Public comments received: 6
    • Preliminary analysis summary (Full Preliminary Analysis)
      • Contribution to program measure set:This measure could help improve the transfer of information about a patient’s medication elements, an important aspect of care transitions. Better care transitions could improve patient outcomes, reduce complications, and lessen the risk of hospital admissions or readmissions.
      • Impact on quality of care for patients:This measure would meet an IMPACT Act requirement, address PAC/LTC core concepts not currently included in the program measure set, and promote alignment across programs.
    • Preliminary analysis result: Conditional support pending NQF endorsement


  4. Transfer of Health Information to Patient—Post-Acute Care (MUC ID: MUC2018-141) (Program: LTCH QRP)
    • Description: The purpose of this measure is to assess for and report on the timely transfer of health information when a patient is discharged from their current setting of care. For this measure, the timely transfer of health information specifically assesses for the transfer of the patient’s current reconciled medication list. This process measure calculates the proportion of patient/resident stays or quality episodes with a discharge/transfer assessment indicating that a current reconciled medication list was provided to the patient, family or caregiver at the time of discharge/transfer. (Measure Specifications)
    • Public comments received: 5
    • Preliminary analysis summary (Full Preliminary Analysis)
      • Contribution to program measure set:This measure could help improve the transfer of information about a patient’s medication elements, an important aspect of care transitions. Better care transitions could improve patient outcomes, reduce complications, and lessen the risk of hospital admissions or readmissions.
      • Impact on quality of care for patients:This measure would meet an IMPACT Act requirement, address PAC/LTC core concepts not currently included in the program measure set, and promote alignment across programs.
    • Preliminary analysis result: Conditional support pending NQF endorsement


12:30 PM   Lunch
1:00 PM   Hospice Quality Reporting Program (HQRP)
  • Overview of HH QRP
  • Opportunity for Public Comment: Measures Under Consideration
  • Feedback on Gaps in the HQRP
Measures under consideration:
  1. Transitions from Hospice Care, Followed by Death or Acute Care (MUC ID: MUC2018-101) (Program: HQRP)
    • Description: This measure will estimate the risk-adjusted rate of transitions from hospice care, followed by death within 30 days or acute care use within 7 days. The measure is risk adjusted to “level the playing field” to allow comparison based on patients with similar characteristics between hospices. The goal of this risk-adjusted measure is to identify hospices that have notably higher rates of negative outcomes, including patient death or acute care following live discharges, when compared to their peers. (Measure Specifications)
    • Public comments received: 5
    • Preliminary analysis summary (Full Preliminary Analysis)
      • Contribution to program measure set:Improved care transitions could improve patient experience and reduce avoidable hospital admissions and readmissions.
      • Impact on quality of care for patients:This measure could address a current quality problem and would add an additional outcome measure to the measure set.
    • Preliminary analysis result: Conditional support pending NQF endorsement


1:50 PM   Promoting Alignment in Measurement of PAC/LTC Care
  • Progress to Date
  • Role of PAC/LTC Core Concepts
  • Guidance on need to setting-specific measures


2:15 PM   Opportunity for Public Comment
2:25 PM   Summary of Day and Next Steps
Gerri Lamb
Paul Mulhausen
Shaconna Gorham


2:30 PM   Adjourn

Appendix A: Measure Information

Measure Index

Home Health Quality Reporting Program

Hospice Quality Reporting Program

Inpatient Rehabilitation Facility Quality Reporting Program

Long-Term Care Hospital Quality Reporting Program

Skilled Nursing Facility Quality Reporting Program


Full Measure Information

Transfer of Health Information to Provider—Post-Acute Care (Program: Home Health Quality Reporting Program; MUC ID: MUC2018-131)

Measure Specifications

Preliminary Analysis of Measure

Rationale for measure provided by HHS
The communication of health information, such as that of a medication list, is critical to ensuring safe and effective patient transitions from one health care setting to another. The focus of this measure is the timely communication of health information, such as medication information at PAC discharge/transfer. Health information that is incomplete or missing, such as medication information, increases the likelihood of a patient/resident safety risk, often life-threatening. [1,2,3,4,5,6] Older adults are particularly vulnerable to adverse health outcomes due to insufficient medication information on the part of their health care providers, and their higher likelihood for multiple comorbid chronic conditions, polypharmacy, and complicated transitions between care settings. [7, 8]. Hospitalized patients discharged to SNFs had an average of 13 medications on their hospital discharge list [9], thus SNF and other PAC providers often are in the position of starting complex new medication regimens with little knowledge of the patient or their medication history. Furthermore, medication discrepancies are common, and found to occur in as many as three quarters of SNF admissions and 86 percent of all transitions.[10,11] Older patients being discharged to settings other than their home were more likely to experience a medication discrepancy, increasing their likelihood of experiencing an adverse event. [12] PAC patients often have complicated medication regimens and require efficient and effective communication and coordination of care between settings, including detailed transfer of medication information. Inter-institutional communication regarding medication regimens is a key factor to improving care transitions and reducing harm to patients. [13,14] Many care transition models, programs, and best practices emphasize the importance of timely communication and information exchange between discharging/ transferring and receiving providers, including medication information. [15,16,17] A comprehensive medication list is an important means of communication this information. The transfer of the patient’s discharge medication information to their next providers and to the patients, in the form of a medication list, is common practice, and supported by discharge planning requirements for participation in Medicare and Medicaid programs. Most PAC EHR systems generate a discharge medication list. However, the content included in the medication lists varies and are not standardized. Other critical medication information may not be included in the medication lists provided at care transitions. Furthermore, these lists are often sent as a hard copy, rather than electronically to the recipient’s EHR system or through interoperable exchange. A pharmacist study identified multiple opportunities to optimize nursing facility discharge medication lists in order to increase patient safety and potentially reduce readmissions. [18]. They noted that nursing facility settings have not made many improvements in discharge medication lists as hospitals have. The pharmacists also identified ideal components of a SNF discharge facility list, including an electronic medication list to minimize human error. An objective of this measure is to improve and standardize the type of medication list information transferred to providers, and, to increase, over time, the secure, timely, electronic transfer of the reconciled medication list using HIT standards. PAC provider adoption of EHRs and participation in health Information exchange can reduce provider burden through the use and reuse of healthcare data, and supports high quality, personalized, and efficient healthcare, care coordination and person-centered care. Further, the interoperability provisions of the 21st Century Cures Act provide a strong framework to enable electronic sharing and interoperable exchange of medication list information. 1. Kwan, J. L., Lo, L., Sampson, M., & Shojania, K. G. (2013). Medication reconciliation during transitions of care as a patient safety strategy: a systematic review. Annals of Internal Medicine, 158(5), 397-403. 2. Boockvar, K. S., Blum, S., Kugler, A., Livote, E., Mergenhagen, K. A., Nebeker, J. R., & Yeh, J. (2011). Effect of admission medication reconciliation on adverse drug events from admission medication changes. Archives of Internal Medicine, 171(9), 860-861. 3. Bell, C. M., Brener, S. S., Gunraj, N., Huo, C., Bierman, A. S., Scales, D. C., & Urbach, D. R. (2011). Association of ICU or hospital admission with unintentional discontinuation of medications for chronic diseases. JAMA, 306(8), 840-847. 4. Basey, A. J., Krska, J., Kennedy, T. D., & Mackridge, A. J. (2014). Prescribing errors on admission to hospital and their potential impact: a mixed-methods study. BMJ Quality & Safety, 23(1), 17-25. 5. Desai, R., Williams, C. E., Greene, S. B., Pierson, S., & Hansen, R. A. (2011). Medication errors during patient transitions into nursing homes: characteristics and association with patient harm. The American Journal of Geriatric Pharmacotherapy, 9(6), 413-422. 6. Boling, P.A. (2009). Care transitions and home health care. Clinical Geriatric Medicine Feb;25(1):135-48. 7. Chhabra, P. T., Rattinger, G. B., Dutcher, S. K., Hare, M. E., Parsons, K., L., & Zuckerman, I. H. (2012). Medication reconciliation during the transition to and from long-term care settings: a systematic review. Res Social Adm Pharm 8(1), 60-75. 8. Levinson, D. R., & General, I. (2014). Adverse events in skilled nursing facilities: national incidence among Medicare beneficiaries. Washington, DC: U.S. Department of Health and Human Services, Office of the Inspector General. 9. Bell, S. P., Vasilevskis, E. E., Saraf, A. A., Jacobsen, J. M. L., Kripalani, S., Mixon, A. S., ... & Simmons, S. F. (2016). Geriatric syndromes in hospitalized older adults discharged to skilled nursing facilities. Journal of the American Geriatrics Society, 64(4), 715-722. 10. Tjia, J., Bonner, A., Briesacher, B. A., McGee, S., Terrill, E., Miller, K. (2009). Medication discrepancies upon hospital to skilled nursing facility transitions. J Gen Intern Med, 24(5), 630-635. 11. Sinvani, L. D., et al. (2013). Medication reconciliation in continuum of care transitions: a moving target. J Am Med Dir Assoc, 14(9), 668-672 12. Manias, E., Annaikis, N., Considine, J., Weerasuriya, R., & Kusljic, S. (2017). Patient-, medication- and environment-related factors affecting medication discrepancies in older patients. Collegian, 24, 571-577. 13. Oakes, S. L., et al. (2011). Transitional care of the long-term care patient. Clin Geriatr Med, 27(2), 259-271. 14. Starmer A. J, Spector N. D., Srivastava R., et al. (2014). Changes in Medical Errors after Implementation of a Handoff Program. N Engl J Med, 37(1), 1803-1812. 15. U.S. Agency for Healthcare Research and Quality. (2016). National healthcare quality and disparities report chartbook on care coordination (Pub. No. 16-0015-6-EF). Rockville, MD: Agency for Healthcare Research and Quality. 16. Murray, L. M., & Laditka, S. B. (2010). Care transitions by older adults from nursing homes to hospitals: Implications for long-term care practice, geriatrics education, and research. Journal of the American Medical Directors Association, 11(4), 231-238. 17. LaMantia, M. A., Scheunemann, L. P., Viera, A. J., Busby-Whitehead, J., & Hanson, L.C. (2010). Interventions to improve transitional care between nursing homes and hospitals: a systematic review. Journal of the American Geriatrics Society, 58(4), 777-782. 18. Backes, A.C., Cash, P., &Jordan, J. (2016). Optimizing the use of discharge medication lists in nursing facilities. Consult Pharm, 31, 493-499.


Transfer of Health Information to Patient—Post-Acute Care (Program: Home Health Quality Reporting Program; MUC ID: MUC2018-135)

Measure Specifications

Preliminary Analysis of Measure

Rationale for measure provided by HHS
The communication of health information, such as that of a medication list, is critical to ensuring safe and effective patient transitions from one health care setting to another. The focus of this measure is the timely communication of health information, such as medication information at PAC discharge/transfer. Incomplete or missing health information such as medications information increases the likelihood of a patient/resident safety risk, often life-threatening. [1,2,3,4,5] Older adults are particularly vulnerable to adverse health outcomes due to insufficient medication information on the part of health care providers due to their higher likelihood for multiple comorbid chronic conditions, polypharmacy, and complicated transitions between care settings. [6] Upon discharge from a post-acute care setting, older adults may be faced with numerous medication changes, appointments, and follow-up details which are especially difficult for individuals with cognitive or functional impairments and/or challenging social circumstances. PAC patients often have complicated medication regimens and require efficient and effective communication and coordination of care between settings, including detailed transfer of medication information to prevent potentially deadly adverse effects. Inter-institutional communication regarding medication regimens is a key factor to improving care transitions and reducing harm to patients. [8] When care transitions are enhanced through care coordination activities, such as expedited patient information flow, these activities can reduce duplication of care services and costs of care, resolve conflicting care plans and prevent medical errors. [9] The transfer of the patient’s discharge medication information to the patient, family, and/or caregiver, in the form of a medication list, is common practice, and supported by discharge planning requirements for participation in Medicare and Medicaid programs. Most PAC EHR systems generate a discharge medication list. However, the content included in the medication lists varies and are not standardized. Other critical medication information may not be included in the medication lists provided to patients at care transitions. Furthermore, these lists may not be written in plain, jargon-free language that the patient understands. A pharmacist study identified multiple opportunities to optimize nursing facility discharge medication lists in order to increase patient safety and potentially reduce readmissions. [10] They noted that nursing facility settings have not made many improvements in discharge medication lists as hospitals have. The pharmacists also identified ideal components of a SNF discharge facility list, providing indications in layperson terms, removing irrelevant information, and maximizing readability. An objective of this measure is to improve and standardize the type of medication list information transferred to patients, and to increase, over time, the secure, timely, electronic transfer of the reconciled medication list electronically (e.g., through patient portals) through PAC EHR systems and using HIT standards. PAC provider adoption of EHRs and participation in health Information exchange can reduce provider burden through the use and reuse of healthcare data, and supports high quality, personalized, and efficient healthcare, care coordination and person-centered care. Further, the interoperability provisions of the 21st Century Cures Act provide a strong framework to enable electronic sharing and interoperable exchange of medication list information. 1. Minto-Pennant, S. (2016). Roadmap to quality: Effective medication reconciliation minimizes errors in a long-term care setting. Journal of the American Medical Directors Association, 17(3), B21-B21. 2. Boockvar, K. S., Blum, S., Kugler, A., Livote, E., Mergenhagen, K. A., Nebeker, J. R., & Yeh, J. (2011). Effect of admission medication reconciliation on adverse drug events from admission medication changes. Archives of Internal Medicine, 171(9), 860-861. 3. Bell, C. M., Brener, S. S., Gunraj, N., Huo, C., Bierman, A. S., Scales, D. C., & Urbach, D. R. (2011). Association of ICU or hospital admission with unintentional discontinuation of medications for chronic diseases. JAMA, 306(8), 840-847. 4. Basey, A. J., Krska, J., Kennedy, T. D., & Mackridge, A. J. (2014). Prescribing errors on admission to hospital and their potential impact: a mixed-methods study. BMJ Quality & Safety, 23(1), 17-25. 5. Desai, R., Williams, C. E., Greene, S. B., Pierson, S., & Hansen, R. A. (2011). Medication errors during patient transitions into nursing homes: characteristics and association with patient harm. The American Journal of Geriatric Pharmacotherapy, 9(6), 413-422. 6. Chhabra, P. T., Rattinger, G. B., Dutcher, S. K., Hare, M. E., Parsons, K., L., & Zuckerman, I. H. (2012). Medication reconciliation during the transition to and from long-term care settings: a systematic review. Res Social Adm Pharm 8(1), 60-75. 7. Oakes, S. L., et al. (2011). Transitional care of the long-term care patient. Clin Geriatr Med, 27(2), 259-271. 8. Mor, V., Intrator, O., Feng, Z., & Grabowski, D. C. (2010). The revolving door of rehospitalization from skilled nursing facilities. Health Affairs, 29(1), 57-64. 9. Starmer A. J, Spector N. D., Srivastava R., et al. (2014). Changes in Medical Errors after Implementation of a Handoff Program. N Engl J Med, 37(1), 1803-1812. 10. Backes, A.C., Cash, P., &Jordan, J. (2016). Optimizing the use of discharge medication lists in nursing facilities. Consult Pharm, 31, 493-499.


Transitions from Hospice Care, Followed by Death or Acute Care (Program: Hospice Quality Reporting Program; MUC ID: MUC2018-101)

Measure Specifications

Preliminary Analysis of Measure

Rationale for measure provided by HHS
Transitions of care are broadly defined as patient movement across healthcare settings, including between providers of care and to and from home. [1] The National Academy of Medicine, formerly called the Institute of Medicine, has described care transitions as particularly vulnerable events for patients. If transitions are poorly coordinated and managed, they can cause poor health care outcomes for patients and lead to wasteful resource use. [2] Measuring transitions among hospice patients and assessing outcomes following transitions from hospice care can therefore provide valuable information about hospices’ quality of care. Transitions from hospice care can occur during a patient’s hospice stay or after a patient is discharged alive from hospice. Care transitions at the end of life are burdensome to patients, families, and the health care system at large because they are associated with adverse health outcomes, [3,4] lower patient and family satisfaction, [5] higher health care costs, [6,7] and fragmentation of care delivery. One national study found that over 10% of all hospice decedents experienced a care transition in the last six months of life, including to hospitals, skilled nursing facilities, home health programs, or home without hospice services. [8] Live discharges from hospice care themselves are considered a type of care transition. Though some patients can be discharged alive from hospice because their clinical status improves or stabilizes, live discharges among patients who are still considered terminally ill can be potentially concerning. A live discharge can lead to a patient dying without comprehensive symptom management and psychosocial support for the patient and family. The national rate of live discharge from hospice has declined in recent years, yet concerns about live discharge persist. The Medicare Payment Advisory Commission (MedPAC) found in their 2018 report that in 2016, 25% of providers had live discharge rates greater than 31% and 10% of providers had rates greater than 53%. The 2016 rates of live discharge among hospices in the 75th and 90th percentile are higher than they were in three preceding years. [9,10] MedPAC suggests that although some level of live discharges from hospice may be appropriate, providers with substantially higher rates of live discharge than their peers may have potential quality issues, such as inability to meet patient and caregiver needs. The report also expressed general support for outcome-based quality measures and specific support for a measure that would capture the live discharge rate and burdensome transitions among hospices. Examining subsequent care transitions and other events that occur after a live discharge from hospice can also reveal potential quality of care issues. Most patients express a wish to die at home and outside of the hospital, and patients discharged alive from hospice are more likely to die in a hospital than patients who receive hospice care up until death. [11,12] A national study of live discharges found that among hospice patients who were discharged alive, nearly a quarter were admitted to the hospital, and a third of those hospitalized following live discharge died within a month of hospice discharge. [13] Many patients reenroll in hospice following live discharge, creating greater burden on patients, caregivers, and the healthcare system, regardless of the patient’s outcome. [14] Live discharges from hospice are expected, for example, in cases where survival improves or patient and family preferences change. However, live discharges from hospice followed shortly by acute care utilization or death represent potentially avoidable and undesirable outcomes, and may indicate potential quality concerns. The issue of care transitions is considered critical by both the public and by hospice stakeholders and policy experts. “Avoiding unnecessary hospital/ED admissions and readmissions” was classified as a “Highly Prioritized Measurement Opportunity for Hospice Care” in NQF’s Performance Measurement Coordination Strategy for Hospice and Palliative Care in 2012. [15] References: 1. The Joint Commission. (2012). Transitions of care: The need for a more effective approach to continuing patient care. Retrieved from: https://www.jointcommission.org/assets/1/18/Hot_Topics_Transitions_of_Care.pdf 2. Burton, R. (2012). Improving care transitions (Health Affairs Health Policy Brief). Retrieved from: https://www.rwjf.org/content/dam/farm/reports/issue_briefs/2012/rwjf401314. 3. Aldridge, M. D., Epstein, A. J., Brody, A. A., Lee, E. J., Cherlin, E., & Bradley, E. H. (2016). The impact of reported hospice preferred practices on hospital utilization at the end of life. Medical Care, 54(7), 657-663. 4. Phongtankuel, V., Scherban, B. A., Reid, M. C., Finley, A., Martin, A., Dennis, J., & Adelman, R. D. (2015). Why do home hospice patients return to the hospital? A study of hospice provider perspectives. Journal of Palliative Medicine, 19(1), 51-56. 5. Dolin, R., Hanson, L. C., Rosenblum, S. F., Stearns, S. C., Holmes, G. M., & Silberman, P. (2017). Factors driving live discharge from hospice: provider perspectives. Journal of Pain and Symptom Management, 53(6), 1050-1056. 6. Carlson, M. D., Herrin, J., Du, Q., Epstein, A. J., Cherlin, E., Morrison, R. S., & Bradley, E. H. (2009). Hospice characteristics and the disenrollment of patients with cancer. Health Services Research, 44(6), 2004-2021. 7. MacKenzie, M. A., & Hanlon, A. (2018). Health-care utilization after hospice enrollment in patients with heart failure and cancer. American Journal of Hospice and Palliative Medicine, 35(2), 229-235. 8. Wang, S.-Y., Aldridge, M. D., Gross, C. P., Canavan, M., Cherlin, E., Johnson-Hurzeler, R., & Bradley, E. (2016). Transitions between healthcare settings of hospice enrollees at the end of life. Journal of the American Geriatrics Society, 64(2), 314-322. 9. Medicare Payment Advisory Commission. (2018). Report to the Congress: Medicare payment policy. pp. 339. Retrieved from: http://medpac.gov/docs/default-source/reports/mar18_medpac_entirereport_sec.pdf?sfvrsn=0 10. Medicare Payment Advisory Commission. (2017). Report to the Congress: Medicare payment policy. pp. 322. Retrieved from: http://medpac.gov/docs/default-source/reports/mar17_entirereport.pdf 11. Institute of Medicine. (2015). Dying in America: Improving quality and honoring individual preferences near the end of life. Retrieved from: https://bmjopen.bmj.com/content/bmjopen/4/7/e005196.full.pdf https://www.nap.edu/read/18748/chapter/1. 12. Pathak, E. B., Wieten, S., & Djulbegovic, B. (2014). From hospice to hospital: Short-term follow-up study of hospice patient outcomes in a US acute care hospital surveillance system. BMJ Open. , 4(7). Retrieved from: https://bmjopen.bmj.com/content/bmjopen/4/7/e005196.full.pdf., 13. Teno, J. M., Bowman, J., Plotzke, M., Gozalo, P. L., Christian, T., Miller, S. C., Williams, C., Mor, V. (2015). Characteristics of hospice programs with problematic live discharges. Journal of Pain and Symptom Management, 50(4), 548-552. 14. Aldridge, M. D., Schlesinger, M., Barry, C. L., Morrison, R. S., McCorkle, R., Hurzeler, R., & Bradley, E. H. (2014). National hospice survey results: for-profit status, community engagement, and service. JAMA Internal Medicine, 174(4), 500-506. 15. Measure Applications Partnership. (2012). Performance measurement coordination strategy for hospice and palliative care. pp. 19-20. Retrieved from: https://www.qualityforum.org/Publications/2012/06/Performance_Measurement_Coordination_Strategy_for_Hospice_and_Palliative_Care.aspx


Transfer of Health Information to Provider—Post-Acute Care (Program: Inpatient Rehabilitation Facility Quality Reporting Program; MUC ID: MUC2018-132)

Measure Specifications

Preliminary Analysis of Measure

Rationale for measure provided by HHS
The communication of health information, such as that of a medication list, is critical to ensuring safe and effective patient transitions from one health care setting to another. The focus of this measure is the timely communication of health information, such as medication information at PAC discharge/transfer. Health information that is incomplete or missing, such as medication information, increases the likelihood of a patient/resident safety risk, often life-threatening. [1,2,3,4,5,6] Older adults are particularly vulnerable to adverse health outcomes due to insufficient medication information on the part of their health care providers, and their higher likelihood for multiple comorbid chronic conditions, polypharmacy, and complicated transitions between care settings. [7, 8]. Hospitalized patients discharged to SNFs had an average of 13 medications on their hospital discharge list [9], thus SNF and other PAC providers often are in the position of starting complex new medication regimens with little knowledge of the patient or their medication history. Furthermore, medication discrepancies are common, and found to occur in as many as three quarters of SNF admissions and 86 percent of all transitions.[10,11] Older patients being discharged to settings other than their home were more likely to experience a medication discrepancy, increasing their likelihood of experiencing an adverse event. [12] PAC patients often have complicated medication regimens and require efficient and effective communication and coordination of care between settings, including detailed transfer of medication information. Inter-institutional communication regarding medication regimens is a key factor to improving care transitions and reducing harm to patients. [13,14] Many care transition models, programs, and best practices emphasize the importance of timely communication and information exchange between discharging/ transferring and receiving providers, including medication information. [15,16,17] A comprehensive medication list is an important means of communication this information. The transfer of the patient’s discharge medication information to their next providers and to the patients, in the form of a medication list, is common practice, and supported by discharge planning requirements for participation in Medicare and Medicaid programs. Most PAC EHR systems generate a discharge medication list. However, the content included in the medication lists varies and are not standardized. Other critical medication information may not be included in the medication lists provided at care transitions. Furthermore, these lists are often sent as a hard copy, rather than electronically to the recipient’s EHR system or through interoperable exchange. A pharmacist study identified multiple opportunities to optimize nursing facility discharge medication lists in order to increase patient safety and potentially reduce readmissions. [18]. They noted that nursing facility settings have not made many improvements in discharge medication lists as hospitals have. The pharmacists also identified ideal components of a SNF discharge facility list, including an electronic medication list to minimize human error. An objective of this measure is to improve and standardize the type of medication list information transferred to providers, and, to increase, over time, the secure, timely, electronic transfer of the reconciled medication list using HIT standards. PAC provider adoption of EHRs and participation in health Information exchange can reduce provider burden through the use and reuse of healthcare data, and supports high quality, personalized, and efficient healthcare, care coordination and person-centered care. Further, the interoperability provisions of the 21st Century Cures Act provide a strong framework to enable electronic sharing and interoperable exchange of medication list information. 1. Kwan, J. L., Lo, L., Sampson, M., & Shojania, K. G. (2013). Medication reconciliation during transitions of care as a patient safety strategy: a systematic review. Annals of Internal Medicine, 158(5), 397-403. 2. Boockvar, K. S., Blum, S., Kugler, A., Livote, E., Mergenhagen, K. A., Nebeker, J. R., & Yeh, J. (2011). Effect of admission medication reconciliation on adverse drug events from admission medication changes. Archives of Internal Medicine, 171(9), 860-861. 3. Bell, C. M., Brener, S. S., Gunraj, N., Huo, C., Bierman, A. S., Scales, D. C., & Urbach, D. R. (2011). Association of ICU or hospital admission with unintentional discontinuation of medications for chronic diseases. JAMA, 306(8), 840-847. 4. Basey, A. J., Krska, J., Kennedy, T. D., & Mackridge, A. J. (2014). Prescribing errors on admission to hospital and their potential impact: a mixed-methods study. BMJ Quality & Safety, 23(1), 17-25. 5. Desai, R., Williams, C. E., Greene, S. B., Pierson, S., & Hansen, R. A. (2011). Medication errors during patient transitions into nursing homes: characteristics and association with patient harm. The American Journal of Geriatric Pharmacotherapy, 9(6), 413-422. 6. Boling, P.A. (2009). Care transitions and home health care. Clinical Geriatric Medicine Feb;25(1):135-48. 7. Chhabra, P. T., Rattinger, G. B., Dutcher, S. K., Hare, M. E., Parsons, K., L., & Zuckerman, I. H. (2012). Medication reconciliation during the transition to and from long-term care settings: a systematic review. Res Social Adm Pharm 8(1), 60-75. 8. Levinson, D. R., & General, I. (2014). Adverse events in skilled nursing facilities: national incidence among Medicare beneficiaries. Washington, DC: U.S. Department of Health and Human Services, Office of the Inspector General. 9. Bell, S. P., Vasilevskis, E. E., Saraf, A. A., Jacobsen, J. M. L., Kripalani, S., Mixon, A. S., ... & Simmons, S. F. (2016). Geriatric syndromes in hospitalized older adults discharged to skilled nursing facilities. Journal of the American Geriatrics Society, 64(4), 715-722. 10. Tjia, J., Bonner, A., Briesacher, B. A., McGee, S., Terrill, E., Miller, K. (2009). Medication discrepancies upon hospital to skilled nursing facility transitions. J Gen Intern Med, 24(5), 630-635. 11. Sinvani, L. D., et al. (2013). Medication reconciliation in continuum of care transitions: a moving target. J Am Med Dir Assoc, 14(9), 668-672 12. Manias, E., Annaikis, N., Considine, J., Weerasuriya, R., & Kusljic, S. (2017). Patient-, medication- and environment-related factors affecting medication discrepancies in older patients. Collegian, 24, 571-577. 13. Oakes, S. L., et al. (2011). Transitional care of the long-term care patient. Clin Geriatr Med, 27(2), 259-271. 14. Starmer A. J, Spector N. D., Srivastava R., et al. (2014). Changes in Medical Errors after Implementation of a Handoff Program. N Engl J Med, 37(1), 1803-1812. 15. U.S. Agency for Healthcare Research and Quality. (2016). National healthcare quality and disparities report chartbook on care coordination (Pub. No. 16-0015-6-EF). Rockville, MD: Agency for Healthcare Research and Quality. 16. Murray, L. M., & Laditka, S. B. (2010). Care transitions by older adults from nursing homes to hospitals: Implications for long-term care practice, geriatrics education, and research. Journal of the American Medical Directors Association, 11(4), 231-238. 17. LaMantia, M. A., Scheunemann, L. P., Viera, A. J., Busby-Whitehead, J., & Hanson, L.C. (2010). Interventions to improve transitional care between nursing homes and hospitals: a systematic review. Journal of the American Geriatrics Society, 58(4), 777-782. 18. Backes, A.C., Cash, P., &Jordan, J. (2016). Optimizing the use of discharge medication lists in nursing facilities. Consult Pharm, 31, 493-499.


Transfer of Health Information to Patient—Post-Acute Care (Program: Inpatient Rehabilitation Facility Quality Reporting Program; MUC ID: MUC2018-139)

Measure Specifications

Preliminary Analysis of Measure

Rationale for measure provided by HHS
The communication of health information, such as that of a reconciled medication list, is critical to ensuring safe and effective patient transitions from one health care setting to another. The focus of this measure is the timely communication of health information, such as medication information at PAC discharge/transfer. Incomplete or missing health information such as medications information increases the likelihood of a patient/resident safety risk, often life-threatening. [1,2,3,4,5] Older adults are particularly vulnerable to adverse health outcomes due to insufficient medication information on the part of health care providers due to their higher likelihood for multiple comorbid chronic conditions, polypharmacy, and complicated transitions between care settings. [6] Upon discharge from a post-acute care setting, older adults may be faced with numerous medication changes, appointments, and follow-up details which are especially difficult for individuals with cognitive or functional impairments and/or challenging social circumstances. PAC patients often have complicated medication regimens and require efficient and effective communication and coordination of care between settings, including detailed transfer of medication information to prevent potentially deadly adverse effects. Inter-institutional communication regarding medication regimens is a key factor to improving care transitions and reducing harm to patients. [8] When care transitions are enhanced through care coordination activities, such as expedited patient information flow, these activities can reduce duplication of care services and costs of care, resolve conflicting care plans and prevent medical errors. [9] The transfer of the patient’s discharge medication information to the patient, family, and/or caregiver, in the form of a list, is common practice, and supported by discharge planning requirements for participation in Medicare and Medicaid programs. Most PAC EHR systems generate a discharge medication list. However, the content included in the medication lists varies and are not standardized. Other critical medication information may not be included in the medication lists provided to patients at care transitions. Furthermore, these lists may not be written in plain, jargon-free language that the patient understands. A pharmacist study identified multiple opportunities to optimize nursing facility discharge medication lists in order to increase patient safety and potentially reduce readmissions. [10] They noted that nursing facility settings have not made many improvements in discharge medication lists as hospitals have. The pharmacists also identified ideal components of a SNF discharge facility list, providing indications in layperson terms, removing irrelevant information, and maximizing readability. An objective of this measure is to improve and standardize the type of medication information transferred to patients, and to increase, over time, the secure, timely, electronic transfer of the medication list electronically (e.g., through patient portals) through PAC EHR systems and using HIT standards. PAC provider adoption of EHRs and participation in health Information exchange can reduce provider burden through the use and reuse of healthcare data, and supports high quality, personalized, and efficient healthcare, care coordination and person-centered care. Further, the interoperability provisions of the 21st Century Cures Act provide a strong framework to enable electronic sharing and interoperable exchange of medication information. 1. Minto-Pennant, S. (2016). Roadmap to quality: Effective medication reconciliation minimizes errors in a long-term care setting. Journal of the American Medical Directors Association, 17(3), B21-B21. 2. Boockvar, K. S., Blum, S., Kugler, A., Livote, E., Mergenhagen, K. A., Nebeker, J. R., & Yeh, J. (2011). Effect of admission medication reconciliation on adverse drug events from admission medication changes. Archives of Internal Medicine, 171(9), 860-861. 3. Bell, C. M., Brener, S. S., Gunraj, N., Huo, C., Bierman, A. S., Scales, D. C., & Urbach, D. R. (2011). Association of ICU or hospital admission with unintentional discontinuation of medications for chronic diseases. JAMA, 306(8), 840-847. 4. Basey, A. J., Krska, J., Kennedy, T. D., & Mackridge, A. J. (2014). Prescribing errors on admission to hospital and their potential impact: a mixed-methods study. BMJ Quality & Safety, 23(1), 17-25. 5. Desai, R., Williams, C. E., Greene, S. B., Pierson, S., & Hansen, R. A. (2011). Medication errors during patient transitions into nursing homes: characteristics and association with patient harm. The American Journal of Geriatric Pharmacotherapy, 9(6), 413-422. 6. Chhabra, P. T., Rattinger, G. B., Dutcher, S. K., Hare, M. E., Parsons, K., L., & Zuckerman, I. H. (2012). Medication reconciliation during the transition to and from long-term care settings: a systematic review. Res Social Adm Pharm 8(1), 60-75. 7. Oakes, S. L., et al. (2011). Transitional care of the long-term care patient. Clin Geriatr Med, 27(2), 259-271. 8. Mor, V., Intrator, O., Feng, Z., & Grabowski, D. C. (2010). The revolving door of rehospitalization from skilled nursing facilities. Health Affairs, 29(1), 57-64. 9. Starmer A. J, Spector N. D., Srivastava R., et al. (2014). Changes in Medical Errors after Implementation of a Handoff Program. N Engl J Med, 37(1), 1803-1812. 10. Backes, A.C., Cash, P., &Jordan, J. (2016). Optimizing the use of discharge medication lists in nursing facilities. Consult Pharm, 31, 493-499.


Transfer of Health Information to Provider—Post-Acute Care (Program: Long-Term Care Hospital Quality Reporting Program; MUC ID: MUC2018-133)

Measure Specifications

Preliminary Analysis of Measure

Rationale for measure provided by HHS
The communication of health information, such as that of a medication list, is critical to ensuring safe and effective patient transitions from one health care setting to another. The focus of this measure is the timely communication of health information, such as medication information at PAC discharge/transfer. Health information that is incomplete or missing, such as medication information, increases the likelihood of a patient/resident safety risk, often life-threatening. [1,2,3,4,5,6] Older adults are particularly vulnerable to adverse health outcomes due to insufficient medication information on the part of their health care providers, and their higher likelihood for multiple comorbid chronic conditions, polypharmacy, and complicated transitions between care settings. [7, 8]. Hospitalized patients discharged to SNFs had an average of 13 medications on their hospital discharge list [9], thus SNF and other PAC providers often are in the position of starting complex new medication regimens with little knowledge of the patient or their medication history. Furthermore, medication discrepancies are common, and found to occur in as many as three quarters of SNF admissions and 86 percent of all transitions.[10,11] Older patients being discharged to settings other than their home were more likely to experience a medication discrepancy, increasing their likelihood of experiencing an adverse event. [12] PAC patients often have complicated medication regimens and require efficient and effective communication and coordination of care between settings, including detailed transfer of medication information. Inter-institutional communication regarding medication regimens is a key factor to improving care transitions and reducing harm to patients. [13,14] Many care transition models, programs, and best practices emphasize the importance of timely communication and information exchange between discharging/ transferring and receiving providers, including medication information. [15,16,17] A comprehensive medication list is an important means of communication this information. The transfer of the patient’s discharge medication information to their next providers and to the patients, in the form of a medication list, is common practice, and supported by discharge planning requirements for participation in Medicare and Medicaid programs. Most PAC EHR systems generate a discharge medication list. However, the content included in the medication lists varies and are not standardized. Other critical medication information may not be included in the medication lists provided at care transitions. Furthermore, these lists are often sent as a hard copy, rather than electronically to the recipient’s EHR system or through interoperable exchange. A pharmacist study identified multiple opportunities to optimize nursing facility discharge medication lists in order to increase patient safety and potentially reduce readmissions. [18]. They noted that nursing facility settings have not made many improvements in discharge medication lists as hospitals have. The pharmacists also identified ideal components of a SNF discharge facility list, including an electronic medication list to minimize human error. An objective of this measure is to improve and standardize the type of medication list information transferred to providers, and, to increase, over time, the secure, timely, electronic transfer of the reconciled medication list using HIT standards. PAC provider adoption of EHRs and participation in health Information exchange can reduce provider burden through the use and reuse of healthcare data, and supports high quality, personalized, and efficient healthcare, care coordination and person-centered care. Further, the interoperability provisions of the 21st Century Cures Act provide a strong framework to enable electronic sharing and interoperable exchange of medication list information. 1. Kwan, J. L., Lo, L., Sampson, M., & Shojania, K. G. (2013). Medication reconciliation during transitions of care as a patient safety strategy: a systematic review. Annals of Internal Medicine, 158(5), 397-403. 2. Boockvar, K. S., Blum, S., Kugler, A., Livote, E., Mergenhagen, K. A., Nebeker, J. R., & Yeh, J. (2011). Effect of admission medication reconciliation on adverse drug events from admission medication changes. Archives of Internal Medicine, 171(9), 860-861. 3. Bell, C. M., Brener, S. S., Gunraj, N., Huo, C., Bierman, A. S., Scales, D. C., & Urbach, D. R. (2011). Association of ICU or hospital admission with unintentional discontinuation of medications for chronic diseases. JAMA, 306(8), 840-847. 4. Basey, A. J., Krska, J., Kennedy, T. D., & Mackridge, A. J. (2014). Prescribing errors on admission to hospital and their potential impact: a mixed-methods study. BMJ Quality & Safety, 23(1), 17-25. 5. Desai, R., Williams, C. E., Greene, S. B., Pierson, S., & Hansen, R. A. (2011). Medication errors during patient transitions into nursing homes: characteristics and association with patient harm. The American Journal of Geriatric Pharmacotherapy, 9(6), 413-422. 6. Boling, P.A. (2009). Care transitions and home health care. Clinical Geriatric Medicine Feb;25(1):135-48. 7. Chhabra, P. T., Rattinger, G. B., Dutcher, S. K., Hare, M. E., Parsons, K., L., & Zuckerman, I. H. (2012). Medication reconciliation during the transition to and from long-term care settings: a systematic review. Res Social Adm Pharm 8(1), 60-75. 8. Levinson, D. R., & General, I. (2014). Adverse events in skilled nursing facilities: national incidence among Medicare beneficiaries. Washington, DC: U.S. Department of Health and Human Services, Office of the Inspector General. 9. Bell, S. P., Vasilevskis, E. E., Saraf, A. A., Jacobsen, J. M. L., Kripalani, S., Mixon, A. S., ... & Simmons, S. F. (2016). Geriatric syndromes in hospitalized older adults discharged to skilled nursing facilities. Journal of the American Geriatrics Society, 64(4), 715-722. 10. Tjia, J., Bonner, A., Briesacher, B. A., McGee, S., Terrill, E., Miller, K. (2009). Medication discrepancies upon hospital to skilled nursing facility transitions. J Gen Intern Med, 24(5), 630-635. 11. Sinvani, L. D., et al. (2013). Medication reconciliation in continuum of care transitions: a moving target. J Am Med Dir Assoc, 14(9), 668-672 12. Manias, E., Annaikis, N., Considine, J., Weerasuriya, R., & Kusljic, S. (2017). Patient-, medication- and environment-related factors affecting medication discrepancies in older patients. Collegian, 24, 571-577. 13. Oakes, S. L., et al. (2011). Transitional care of the long-term care patient. Clin Geriatr Med, 27(2), 259-271. 14. Starmer A. J, Spector N. D., Srivastava R., et al. (2014). Changes in Medical Errors after Implementation of a Handoff Program. N Engl J Med, 37(1), 1803-1812. 15. U.S. Agency for Healthcare Research and Quality. (2016). National healthcare quality and disparities report chartbook on care coordination (Pub. No. 16-0015-6-EF). Rockville, MD: Agency for Healthcare Research and Quality. 16. Murray, L. M., & Laditka, S. B. (2010). Care transitions by older adults from nursing homes to hospitals: Implications for long-term care practice, geriatrics education, and research. Journal of the American Medical Directors Association, 11(4), 231-238. 17. LaMantia, M. A., Scheunemann, L. P., Viera, A. J., Busby-Whitehead, J., & Hanson, L.C. (2010). Interventions to improve transitional care between nursing homes and hospitals: a systematic review. Journal of the American Geriatrics Society, 58(4), 777-782. 18. Backes, A.C., Cash, P., &Jordan, J. (2016). Optimizing the use of discharge medication lists in nursing facilities. Consult Pharm, 31, 493-499.


Transfer of Health Information to Patient—Post-Acute Care (Program: Long-Term Care Hospital Quality Reporting Program; MUC ID: MUC2018-141)

Measure Specifications

Preliminary Analysis of Measure

Rationale for measure provided by HHS
The communication of health information, such as that of a reconciled medication list, is critical to ensuring safe and effective patient transitions from one health care setting to another. The focus of this measure is the timely communication of health information, such as medication information at PAC discharge/transfer. Incomplete or missing health information such as medications information increases the likelihood of a patient/resident safety risk, often life-threatening. [1,2,3,4,5] Older adults are particularly vulnerable to adverse health outcomes due to insufficient medication information on the part of health care providers due to their higher likelihood for multiple comorbid chronic conditions, polypharmacy, and complicated transitions between care settings. [6] Upon discharge from a post-acute care setting, older adults may be faced with numerous medication changes, appointments, and follow-up details which are especially difficult for individuals with cognitive or functional impairments and/or challenging social circumstances. PAC patients often have complicated medication regimens and require efficient and effective communication and coordination of care between settings, including detailed transfer of medication information to prevent potentially deadly adverse effects. Inter-institutional communication regarding medication regimens is a key factor to improving care transitions and reducing harm to patients. [8] When care transitions are enhanced through care coordination activities, such as expedited patient information flow, these activities can reduce duplication of care services and costs of care, resolve conflicting care plans and prevent medical errors. [9] The transfer of the patient’s discharge medication information to the patient, family, and/or caregiver, in the form of a list, is common practice, and supported by discharge planning requirements for participation in Medicare and Medicaid programs. Most PAC EHR systems generate a discharge medication list. However, the content included in the medication lists varies and are not standardized. Other critical medication information may not be included in the medication lists provided to patients at care transitions. Furthermore, these lists may not be written in plain, jargon-free language that the patient understands. A pharmacist study identified multiple opportunities to optimize nursing facility discharge medication lists in order to increase patient safety and potentially reduce readmissions. [10] They noted that nursing facility settings have not made many improvements in discharge medication lists as hospitals have. The pharmacists also identified ideal components of a SNF discharge facility list, providing indications in layperson terms, removing irrelevant information, and maximizing readability. An objective of this measure is to improve and standardize the type of medication information transferred to patients, and to increase, over time, the secure, timely, electronic transfer of the medication list electronically (e.g., through patient portals) through PAC EHR systems and using HIT standards. PAC provider adoption of EHRs and participation in health Information exchange can reduce provider burden through the use and reuse of healthcare data, and supports high quality, personalized, and efficient healthcare, care coordination and person-centered care. Further, the interoperability provisions of the 21st Century Cures Act provide a strong framework to enable electronic sharing and interoperable exchange of medication information. 1. Minto-Pennant, S. (2016). Roadmap to quality: Effective medication reconciliation minimizes errors in a long-term care setting. Journal of the American Medical Directors Association, 17(3), B21-B21. 2. Boockvar, K. S., Blum, S., Kugler, A., Livote, E., Mergenhagen, K. A., Nebeker, J. R., & Yeh, J. (2011). Effect of admission medication reconciliation on adverse drug events from admission medication changes. Archives of Internal Medicine, 171(9), 860-861. 3. Bell, C. M., Brener, S. S., Gunraj, N., Huo, C., Bierman, A. S., Scales, D. C., & Urbach, D. R. (2011). Association of ICU or hospital admission with unintentional discontinuation of medications for chronic diseases. JAMA, 306(8), 840-847. 4. Basey, A. J., Krska, J., Kennedy, T. D., & Mackridge, A. J. (2014). Prescribing errors on admission to hospital and their potential impact: a mixed-methods study. BMJ Quality & Safety, 23(1), 17-25. 5. Desai, R., Williams, C. E., Greene, S. B., Pierson, S., & Hansen, R. A. (2011). Medication errors during patient transitions into nursing homes: characteristics and association with patient harm. The American Journal of Geriatric Pharmacotherapy, 9(6), 413-422. 6. Chhabra, P. T., Rattinger, G. B., Dutcher, S. K., Hare, M. E., Parsons, K., L., & Zuckerman, I. H. (2012). Medication reconciliation during the transition to and from long-term care settings: a systematic review. Res Social Adm Pharm 8(1), 60-75. 7. Oakes, S. L., et al. (2011). Transitional care of the long-term care patient. Clin Geriatr Med, 27(2), 259-271. 8. Mor, V., Intrator, O., Feng, Z., & Grabowski, D. C. (2010). The revolving door of rehospitalization from skilled nursing facilities. Health Affairs, 29(1), 57-64. 9. Starmer A. J, Spector N. D., Srivastava R., et al. (2014). Changes in Medical Errors after Implementation of a Handoff Program. N Engl J Med, 37(1), 1803-1812. 10. Backes, A.C., Cash, P., &Jordan, J. (2016). Optimizing the use of discharge medication lists in nursing facilities. Consult Pharm, 31, 493-499.


Transfer of Health Information to Provider—Post-Acute Care (Program: Skilled Nursing Facility Quality Reporting Program; MUC ID: MUC2018-136)

Measure Specifications

Preliminary Analysis of Measure

Rationale for measure provided by HHS
The communication of health information, such as that of a medication list, is critical to ensuring safe and effective patient transitions from one health care setting to another. The focus of this measure is the timely communication of health information, such as medication information at PAC discharge/transfer. Health information that is incomplete or missing, such as medication information, increases the likelihood of a patient/resident safety risk, often life-threatening. [1,2,3,4,5,6] Older adults are particularly vulnerable to adverse health outcomes due to insufficient medication information on the part of their health care providers, and their higher likelihood for multiple comorbid chronic conditions, polypharmacy, and complicated transitions between care settings. [7, 8]. Hospitalized patients discharged to SNFs had an average of 13 medications on their hospital discharge list [9], thus SNF and other PAC providers often are in the position of starting complex new medication regimens with little knowledge of the patient or their medication history. Furthermore, medication discrepancies are common, and found to occur in as many as three quarters of SNF admissions and 86 percent of all transitions.[10,11] Older patients being discharged to settings other than their home were more likely to experience a medication discrepancy, increasing their likelihood of experiencing an adverse event. [12] PAC patients often have complicated medication regimens and require efficient and effective communication and coordination of care between settings, including detailed transfer of medication information. Inter-institutional communication regarding medication regimens is a key factor to improving care transitions and reducing harm to patients. [13,14] Many care transition models, programs, and best practices emphasize the importance of timely communication and information exchange between discharging/ transferring and receiving providers, including medication information. [15,16,17] A comprehensive medication list is an important means of communication this information. The transfer of the patient’s discharge medication information to their next providers and to the patients, in the form of a medication list, is common practice, and supported by discharge planning requirements for participation in Medicare and Medicaid programs. Most PAC EHR systems generate a discharge medication list. However, the content included in the medication lists varies and are not standardized. Other critical medication information may not be included in the medication lists provided at care transitions. Furthermore, these lists are often sent as a hard copy, rather than electronically to the recipient’s EHR system or through interoperable exchange. A pharmacist study identified multiple opportunities to optimize nursing facility discharge medication lists in order to increase patient safety and potentially reduce readmissions. [18]. They noted that nursing facility settings have not made many improvements in discharge medication lists as hospitals have. The pharmacists also identified ideal components of a SNF discharge facility list, including an electronic medication list to minimize human error. An objective of this measure is to improve and standardize the type of medication list information transferred to providers, and, to increase, over time, the secure, timely, electronic transfer of the reconciled medication list using HIT standards. PAC provider adoption of EHRs and participation in health Information exchange can reduce provider burden through the use and reuse of healthcare data, and supports high quality, personalized, and efficient healthcare, care coordination and person-centered care. Further, the interoperability provisions of the 21st Century Cures Act provide a strong framework to enable electronic sharing and interoperable exchange of medication list information. 1. Kwan, J. L., Lo, L., Sampson, M., & Shojania, K. G. (2013). Medication reconciliation during transitions of care as a patient safety strategy: a systematic review. Annals of Internal Medicine, 158(5), 397-403. 2. Boockvar, K. S., Blum, S., Kugler, A., Livote, E., Mergenhagen, K. A., Nebeker, J. R., & Yeh, J. (2011). Effect of admission medication reconciliation on adverse drug events from admission medication changes. Archives of Internal Medicine, 171(9), 860-861. 3. Bell, C. M., Brener, S. S., Gunraj, N., Huo, C., Bierman, A. S., Scales, D. C., & Urbach, D. R. (2011). Association of ICU or hospital admission with unintentional discontinuation of medications for chronic diseases. JAMA, 306(8), 840-847. 4. Basey, A. J., Krska, J., Kennedy, T. D., & Mackridge, A. J. (2014). Prescribing errors on admission to hospital and their potential impact: a mixed-methods study. BMJ Quality & Safety, 23(1), 17-25. 5. Desai, R., Williams, C. E., Greene, S. B., Pierson, S., & Hansen, R. A. (2011). Medication errors during patient transitions into nursing homes: characteristics and association with patient harm. The American Journal of Geriatric Pharmacotherapy, 9(6), 413-422. 6. Boling, P.A. (2009). Care transitions and home health care. Clinical Geriatric Medicine Feb;25(1):135-48. 7. Chhabra, P. T., Rattinger, G. B., Dutcher, S. K., Hare, M. E., Parsons, K., L., & Zuckerman, I. H. (2012). Medication reconciliation during the transition to and from long-term care settings: a systematic review. Res Social Adm Pharm 8(1), 60-75. 8. Levinson, D. R., & General, I. (2014). Adverse events in skilled nursing facilities: national incidence among Medicare beneficiaries. Washington, DC: U.S. Department of Health and Human Services, Office of the Inspector General. 9. Bell, S. P., Vasilevskis, E. E., Saraf, A. A., Jacobsen, J. M. L., Kripalani, S., Mixon, A. S., ... & Simmons, S. F. (2016). Geriatric syndromes in hospitalized older adults discharged to skilled nursing facilities. Journal of the American Geriatrics Society, 64(4), 715-722. 10. Tjia, J., Bonner, A., Briesacher, B. A., McGee, S., Terrill, E., Miller, K. (2009). Medication discrepancies upon hospital to skilled nursing facility transitions. J Gen Intern Med, 24(5), 630-635. 11. Sinvani, L. D., et al. (2013). Medication reconciliation in continuum of care transitions: a moving target. J Am Med Dir Assoc, 14(9), 668-672 12. Manias, E., Annaikis, N., Considine, J., Weerasuriya, R., & Kusljic, S. (2017). Patient-, medication- and environment-related factors affecting medication discrepancies in older patients. Collegian, 24, 571-577. 13. Oakes, S. L., et al. (2011). Transitional care of the long-term care patient. Clin Geriatr Med, 27(2), 259-271. 14. Starmer A. J, Spector N. D., Srivastava R., et al. (2014). Changes in Medical Errors after Implementation of a Handoff Program. N Engl J Med, 37(1), 1803-1812. 15. U.S. Agency for Healthcare Research and Quality. (2016). National healthcare quality and disparities report chartbook on care coordination (Pub. No. 16-0015-6-EF). Rockville, MD: Agency for Healthcare Research and Quality. 16. Murray, L. M., & Laditka, S. B. (2010). Care transitions by older adults from nursing homes to hospitals: Implications for long-term care practice, geriatrics education, and research. Journal of the American Medical Directors Association, 11(4), 231-238. 17. LaMantia, M. A., Scheunemann, L. P., Viera, A. J., Busby-Whitehead, J., & Hanson, L.C. (2010). Interventions to improve transitional care between nursing homes and hospitals: a systematic review. Journal of the American Geriatrics Society, 58(4), 777-782. 18. Backes, A.C., Cash, P., &Jordan, J. (2016). Optimizing the use of discharge medication lists in nursing facilities. Consult Pharm, 31, 493-499.


Transfer of Health Information to Patient—Post-Acute Care (Program: Skilled Nursing Facility Quality Reporting Program; MUC ID: MUC2018-138)

Measure Specifications

Preliminary Analysis of Measure

Rationale for measure provided by HHS
The communication of health information, such as that of a reconciled medication list, is critical to ensuring safe and effective patient transitions from one health care setting to another. The focus of this measure is the timely communication of health information, such as medication information at PAC discharge/transfer. Incomplete or missing health information such as medications information increases the likelihood of a patient/resident safety risk, often life-threatening. [1,2,3,4,5] Older adults are particularly vulnerable to adverse health outcomes due to insufficient medication information on the part of health care providers due to their higher likelihood for multiple comorbid chronic conditions, polypharmacy, and complicated transitions between care settings. [6] Upon discharge from a post-acute care setting, older adults may be faced with numerous medication changes, appointments, and follow-up details which are especially difficult for individuals with cognitive or functional impairments and/or challenging social circumstances. PAC patients often have complicated medication regimens and require efficient and effective communication and coordination of care between settings, including detailed transfer of medication information to prevent potentially deadly adverse effects. Inter-institutional communication regarding medication regimens is a key factor to improving care transitions and reducing harm to patients. [8] When care transitions are enhanced through care coordination activities, such as expedited patient information flow, these activities can reduce duplication of care services and costs of care, resolve conflicting care plans and prevent medical errors. [9] The transfer of the patient’s discharge medication information to the patient, family, and/or caregiver, in the form of a list, is common practice, and supported by discharge planning requirements for participation in Medicare and Medicaid programs. Most PAC EHR systems generate a discharge medication list. However, the content included in the medication lists varies and are not standardized. Other critical medication information may not be included in the medication lists provided to patients at care transitions. Furthermore, these lists may not be written in plain, jargon-free language that the patient understands. A pharmacist study identified multiple opportunities to optimize nursing facility discharge medication lists in order to increase patient safety and potentially reduce readmissions. [10] They noted that nursing facility settings have not made many improvements in discharge medication lists as hospitals have. The pharmacists also identified ideal components of a SNF discharge facility list, providing indications in layperson terms, removing irrelevant information, and maximizing readability. An objective of this measure is to improve and standardize the type of medication information transferred to patients, and to increase, over time, the secure, timely, electronic transfer of the medication list electronically (e.g., through patient portals) through PAC EHR systems and using HIT standards. PAC provider adoption of EHRs and participation in health Information exchange can reduce provider burden through the use and reuse of healthcare data, and supports high quality, personalized, and efficient healthcare, care coordination and person-centered care. Further, the interoperability provisions of the 21st Century Cures Act provide a strong framework to enable electronic sharing and interoperable exchange of medication information. 1. Minto-Pennant, S. (2016). Roadmap to quality: Effective medication reconciliation minimizes errors in a long-term care setting. Journal of the American Medical Directors Association, 17(3), B21-B21. 2. Boockvar, K. S., Blum, S., Kugler, A., Livote, E., Mergenhagen, K. A., Nebeker, J. R., & Yeh, J. (2011). Effect of admission medication reconciliation on adverse drug events from admission medication changes. Archives of Internal Medicine, 171(9), 860-861. 3. Bell, C. M., Brener, S. S., Gunraj, N., Huo, C., Bierman, A. S., Scales, D. C., & Urbach, D. R. (2011). Association of ICU or hospital admission with unintentional discontinuation of medications for chronic diseases. JAMA, 306(8), 840-847. 4. Basey, A. J., Krska, J., Kennedy, T. D., & Mackridge, A. J. (2014). Prescribing errors on admission to hospital and their potential impact: a mixed-methods study. BMJ Quality & Safety, 23(1), 17-25. 5. Desai, R., Williams, C. E., Greene, S. B., Pierson, S., & Hansen, R. A. (2011). Medication errors during patient transitions into nursing homes: characteristics and association with patient harm. The American Journal of Geriatric Pharmacotherapy, 9(6), 413-422. 6. Chhabra, P. T., Rattinger, G. B., Dutcher, S. K., Hare, M. E., Parsons, K., L., & Zuckerman, I. H. (2012). Medication reconciliation during the transition to and from long-term care settings: a systematic review. Res Social Adm Pharm 8(1), 60-75. 7. Oakes, S. L., et al. (2011). Transitional care of the long-term care patient. Clin Geriatr Med, 27(2), 259-271. 8. Mor, V., Intrator, O., Feng, Z., & Grabowski, D. C. (2010). The revolving door of rehospitalization from skilled nursing facilities. Health Affairs, 29(1), 57-64. 9. Starmer A. J, Spector N. D., Srivastava R., et al. (2014). Changes in Medical Errors after Implementation of a Handoff Program. N Engl J Med, 37(1), 1803-1812. 10. Backes, A.C., Cash, P., &Jordan, J. (2016). Optimizing the use of discharge medication lists in nursing facilities. Consult Pharm, 31, 493-499.



Appendix B: Program Summaries

The material in this appendix was drawn from the CMS Program Specific Measure Priorities and Needs document, which was released in May 2018.

Program Index


Full Program Summaries

Inpatient Rehabilitation Facility Quality Reporting Program 
The material in this appendix was drawn from the CMS Program Specific Measure Priorities and Needs document, which was released in May 2018.

Program History and Structure: The Quality Reporting Program (QRP) for Inpatient Rehabilitation Facilities (IRFs) was established in accordance with section 1886(j) of the Social Security Act as amended by section 3004(b) of the Affordable Care Act. The IRF QRP applies to all IRF facilities that receive the IRF PPS (e.g., IRF hospitals, IRF units that are co-located with affiliated acute care facilities, and IRF units affiliated with critical access hospitals [CAHs]). Data sources for IRF QRP measures include Medicare FFS claims, the Center for Disease Control’s National Health Safety Network (CDC NHSN) data submissions, and Inpatient Rehabilitation Facility - Patient Assessment instrument (IRF-PAI) records. The IRF QRP measure development and selection activities take into account established national priorities and input from multi-stakeholder groups. Beginning in FY 2014, IRFs that fail to submit data will be subject to a 2.0 percentage point reduction of the applicable IRF Prospective Payment System (PPS) payment update. Plans for future public reporting of IRF QRP measures are under development. Further, the Improving Medicare Post-Acute Care Transformation of 2014 (IMPACT Act) amends title XVIII (Medicare) of the Social Security Act (the Act) to direct the Secretary of the Department of Health and Human Services (HHS) to require Long-term Care Hospitals (LTCHs), Inpatient Rehabilitation Facilities (IRFs), Skilled Nursing Facilities (SNFs) and Home Health Agencies (HHAs) to report standardized patient assessment data, data on quality measures including resource use measures. The development of standardized data stems from specified assessment domains via the assessment instruments that are used to submit assessment data to CMS by these post-acute care (PAC) providers. The IMPACT Act requires CMS to develop and implement quality measures from five measure domains: functional status, cognitive function, and changes in function and cognitive function; skin integrity and changes in skin integrity; medication reconciliation; incidence of major falls; and the transfer of health information when the individual transitions from the hospital/critical access hospital to PAC provider or home, or from PAC provider to another settings. The IMPACT Act also delineates the implementation of resource use and other measures in at least these following domains: total estimated Medicare spending per beneficiary; discharge to the community; and all condition risk adjusted potentially preventable hospital readmission rates.

High Priority Domains for Future Measure Consideration:

CMS identified the following domain as high-priority for future measure consideration:

Communication/Care Coordination: The communication of health information such as medication profiles is critical to ensuring safe and effective transitions from one health care setting to another. Medication errors, poor communication, and poor coordination between providers, along with the rising incidence of preventable adverse events and hospital readmissions emphasize the importance of the timely transfer of health information and care preferences at transitions.

Current Measures: NQF staff have compiled the program's measures in a spreadsheet organized according to concepts.

Skilled Nursing Facility Quality Reporting Program 
The material in this appendix was drawn from the CMS Program Specific Measure Priorities and Needs document, which was released in May 2018.

Program History and Structure: The Improving Medicare Post-Acute Care Transitions Act of 2014 (The IMPACT Act) added Section 1899B to the Social Security Act establishing the Skilled Nursing Facility Quality Reporting Program (SNF QRP). Facilities that submit data under the SNF PPS are required to participate in the SNF QRP, excluding units that are affiliated with critical access hospitals (CAHs). Data sources for SNF QRP measures include Medicare FFS claims as well as Minimum Data Set (MDS) assessment data. The SNF QRP measure development and selection activities take into account established national priorities and input from multi-stakeholder groups. Beginning in FY 2018, providers that fail to submit required quality data to CMS will have their annual updates reduced by 2.0 percentage points. Further, the Improving Medicare Post-Acute Care Transformation of 2014 (IMPACT Act) amends title XVIII (Medicare) of the Social Security Act (the Act) to direct the Secretary of the Department of Health and Human Services (HHS) to require Long-term Care Hospitals (LTCHs), Inpatient Rehabilitation Facilities (IRFs), Skilled Nursing Facilities (SNFs), and Home Health Agencies (HHAs) to report standardized patient assessment data, data on quality measures including resource use measures. The development of standardized data stems from specified assessment domains via the assessment instruments that are used to submit assessment data to CMS by these post-acute care (PAC) providers. The IMPACT Act requires CMS to develop and implement quality measures from five measure domains: functional status, cognitive function, and changes in function and cognitive function; skin integrity and changes in skin integrity; medication reconciliation; incidence of major falls; and the transfer of health information when the individual transitions from the hospital/critical access hospital to PAC provider or home, or from PAC provider to another settings. The IMPACT Act also delineates the implementation of resource use and other measures in at least these following domains: total estimated Medicare spending per beneficiary; discharge to the community; and all condition risk adjusted potentially preventable hospital readmission rates.

High Priority Domains for Future Measure Consideration:

CMS identified the following domain as high-priority for future measure consideration:
  1. Communication/Care Coordination: Transfer of Health Information and Interoperability: The communication of health information such as medication profiles is critical to ensuring safe and effective transitions from one health care setting to another. Medication errors, poor communication, and poor coordination between providers, along with the rising incidence of preventable adverse events and hospital readmissions emphasize the importance of the timely transfer of health information and care preferences at transitions.

Current Measures: NQF staff have compiled the program's measures in a spreadsheet organized according to concepts.

Home Health Quality Reporting Program 
The material in this appendix was drawn from the CMS Program Specific Measure Priorities and Needs document, which was released in May 2018.

Program History and Structure: The Home Health Quality Reporting Program (HH QRP) was established in accordance with section 1895 (b)(3)(B)(v)(II) of the Social Security Act. Home Health Agencies (HHAs) are required by the Act to submit quality data for use in evaluating quality for Home Health agencies. Section 1895(b) (3)(B)(v)(I) of the Act also requires that HHAs that do not submit quality data to the Secretary be subject to a 2 percent reduction in the annual payment update, effective in calendar year 2007 and every subsequent year. Data sources for the HH QRP include the Outcome and Assessment Information Set (OASIS) and Medicare FFS claims. Data is publically reported on the Home Health Compare website. The HH QRP measure development and selection activities take into account established national priorities and input from multi-stakeholder groups. Further, the Improving Medicare Post-Acute Care Transformation of 2014 (IMPACT Act) amends title XVIII (Medicare) of the Social Security Act (the Act) to direct the Secretary of the Department of Health and Human Services (HHS) to require Long-term Care Hospitals (LTCHs), Inpatient Rehabilitation Facilities (IRFs), Skilled Nursing Facilities (SNFs) and Home Health Agencies (HHAs) to report standardized patient assessment data, data on quality measures including resource use measures. The development of standardized data stems from specified assessment domains via the assessment instruments that are used to submit assessment data to CMS by these post-acute care (PAC) providers. The IMPACT Act requires CMS to develop and implement quality measures from five measure domains: functional status, cognitive function, and changes in function and cognitive function; skin integrity and changes in skin integrity; medication reconciliation; incidence of major falls; and the transfer of health information when the individual transitions from the hospital/critical access hospital to PAC provider or home, or from PAC provider to another settings. The IMPACT Act also delineates the implementation of resource use and other measures in at least these following domains: total estimated Medicare spending per beneficiary; discharge to the community; and all condition risk adjusted potentially preventable hospital readmission rates.

High Priority Domains for Future Measure Consideration:

CMS identified the following domains as high-priority for future measure consideration:

  1. Patient and Family Engagement: Care is Personalize and Aligned with Patients' Goals: Functional status and preventing functional decline are important priorities for to assess for home health patients. Patients who receive care while in a home health may have functional limitations, individual functional goals and may be at risk for further decline in function due to limited mobility and ambulation.
  2. Communication/Care Coordination: The communication of health information such as medication profiles is critical to ensuring safe and effective transitions from one health care setting to another. Medication errors, poor communication, and poor coordination between providers, along with the rising incidence of preventable adverse events and hospital readmissions emphasize the importance of the timely transfer of health information and care preferences at transitions.
  3. Current Measures: NQF staff have compiled the program's measures in a spreadsheet organized according to concepts.

    Long-Term Care Hospital Quality Reporting Program 
    The material in this appendix was drawn from the CMS Program Specific Measure Priorities and Needs document, which was released in May 2018.

    Program History and Structure: The Long-Term Care Hospital (LTCH) Quality Reporting Program (QRP) was established in accordance with section 1886(m) of the Social Security Act, as amended by Section 3004(a) of the Affordable Care Act. The LTCH QRP applies to all LTCHs facilities designated as an LTCH under the Medicare program. Data sources for LTCH QRP measures include Medicare FFS claims, the Center for Disease Control and Prevention’s National Health Safety Network (CDC’s NHSN) data submissions, and the LTCH Continuity Assessment Record and Evaluation Data Sets (LCDS). The LTCH QRP measure development and selection activities take into account established national priorities and input from multi-stakeholder groups. Beginning in FY 2014, LTCHs that fail to submit data will be subject to a 2.0 percentage point reduction of the applicable Prospective Payment System (PPS) increase factor. Further, the Improving Medicare Post-Acute Care Transformation of 2014 (IMPACT Act) amends title XVIII (Medicare) of the Social Security Act (the Act) to direct the Secretary of the Department of Health and Human Services (HHS) to require Long-term Care Hospitals (LTCHs), Inpatient Rehabilitation Facilities (IRFs), Skilled Nursing Facilities (SNFs) and Home Health Agencies (HHAs) to report standardized patient assessment data, data on quality measures including resource use measures. The development of standardized data stems from specified assessment domains via the assessment instruments that are used to submit assessment data to CMS by these post-acute care (PAC) providers. The IMPACT Act requires CMS to develop and implement quality measures from five measure domains: functional status, cognitive function, and changes in function and cognitive function; skin integrity and changes in skin integrity; medication reconciliation; incidence of major falls; and the transfer of health information when the individual transitions from the hospital/critical access hospital to PAC provider or home, or from PAC provider to another settings. The IMPACT Act also delineates the implementation of resource use and other measures in at least these following domains: total estimated Medicare spending per beneficiary; discharge to the community; and all condition risk adjusted potentially preventable hospital readmission rates.

    High Priority Domains for Future Measure Consideration:

    CMS identified the following domain as high-priority for LTCH QRP future measure consideration:

    1. Communication/Care Coordination: Transfer of Health Information and Interoperability: The communication of health information such as medication profiles is critical to ensuring safe and effective transitions from one health care setting to another. Medication errors, poor communication, and poor coordination between providers, along with the rising incidence of preventable adverse events and hospital readmissions emphasize the importance of the timely transfer of health information and care preferences at transitions.

      Current Measures: NQF staff have compiled the program's measures in a spreadsheet organized according to concepts.

      The material in this appendix was drawn from the CMS Program Specific Measure Priorities and Needs document, which was released in May 2018.

      Program History and Structure: The Hospice Quality Reporting Program (HQRP) was established in accordance with section 1814(i) of the Social Security Act, as amended by section 3004(c) of the Affordable Care Act. The HQRP applies to all hospices, regardless of setting. Proposed data sources for future HQRP measures include the Hospice Item Set and the Hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey. HQRP measure development and selection activities take into account established national priorities and input from multi-stakeholder groups. Beginning in FY 2014, Hospices that fail to submit quality data will be subject to a 2.0 percentage point reduction to their annual payment update.

      High Priority Domains for Future Measure Consideration:

      CMS identified the following domains as high-priority for HQRP future measure consideration:
      1. Effective Prevention and Treatment: Symptom Management Outcome Measures are a high priority for the HQRP. There is a lack of tested and endorsed outcome measures for hospice across domains of hospice care, including symptom management (e.g.; physical and other symptoms). Developing and implementing outcome measures for hospice is important for providers, patients and families, and other stakeholders because symptom management is a central aspect of hospice care.
      2. Communication/Care Coordination and/or Patient and Family Engagement: Patient preference for care is difficult to measure at end of life when patients may or may not be able to state their preferences, and may have changes in their preferences. However, a central tenet of hospice care is responsiveness to patient and family care preferences; as much as possible, patient preferences should be incorporated into new measure development.
      3. Making Care Safer: Timeliness/responsiveness of care. While timeliness of referral to hospice is not within a hospices’ control, hospice initiation of treatment once a patient has elected the hospice benefit is under the control of the hospice. Responsiveness of the hospice during timeof patient or family need is an important indicator about hospice services for consumers in particular.
      4. Communication/Care Coordination: Measurement of care coordination is integral to the provision of quality care and should be aligned across care settings.

      Current Measures: NQF staff have compiled the program's measures in a spreadsheet organized according to concepts.


      Appendix C: Public Comments

      Index of Measures (by Program)

      All measures are included in the index, even if there were not any public comments about that measure for that program.

      Home Health Quality Reporting Program

      Hospice Quality Reporting Program

      Inpatient Rehabilitation Facility Quality Reporting Program

      Long-Term Care Hospital Quality Reporting Program

      Skilled Nursing Facility Quality Reporting Program


      Full Comments (Listed by Measure)

      Transitions from Hospice Care, Followed by Death or Acute Care (Program: Hospice Quality Reporting Program; MUC ID: MUC2018-101)
      • VIA: http://www.qualityforum.org/map/ December 6, 2018 Public Comment 2018 Measures Under Consideration Submitted via: Since 1982, the National Association for Home Care & Hospice (NAHC) has been the leading association representing the interests of hospices, home health, and home care providers across the nation, including the home caregiving staff and the patients and families they serve. Our members are providers of all sizes and types -- from small rural agencies to large national companies -- and include government-based providers, nonprofit voluntary hospices, privately-owned companies and public corporations. As such, we welcome the opportunity to comment on the CMS List of Measures Under Consideration for December 1, 2018. We are commenting on the following three measures: MUC18- 101 Transitions from Hospice Care, Followed by Death or Acute Care MUC18- 131 Transfer of Health Information to Patient—PostAcute Care MUC18- 135 Transfer of Health Information to Provider—PostAcute Care MUC18- 101 Transitions from Hospice Care, Followed by Death or Acute Care As we commented to CMS directly in 2018, we believe this measure falls short of providing a direct indicator of quality of care, has significant potential unintended consequences the least of which is confusion about a hospice’s performance amongst consumers. This raises concern, particularly relative to use of this measure for public reporting. We appreciate and understand the intent of this measure which is to assess negative outcomes following hospice live discharge, including acute care use shortly after discharge, as these outcomes represent potentially burdensome transitions to patients and families. We also appreciate the considerable expansion by CMS of the risk adjustment factors, based on previous public comment, to include a patient’s prior use of acute care services, social risk factors, setting of care while receiving hospice care, etc. We further appreciate that CMS would potentially plan a dry run of this measure, as indicated in its public comment summary report for this measure (August 2018), to determine if the measure is appropriate for public reporting. There is considerable potential for misunderstanding of this measure, and consequent unintended negative consequences. This was emphasized in the comments CMS received, and in its response, CMS stated “Finally, additional measure testing and refinement, including a potential measure dry run will aim to further address the potential unintended consequences of the measure.” We believe this additional measure testing and refinement is crucial to making the measure meaningful to providers and for providers to utilize the measure to inform improvement actions. The current measure specifications exclude the following types of patients: 1. Patients not continuously enrolled in Part A Medicare FFS in the 12 months prior to the hospice admission date, during the hospice stay, or at least 7 days following the hospice discharge date 2. Patients enrolled in Medicare Advantage in the 12 months prior to the hospice admission date, during the hospice stay, or in the 7 days following the hospice discharge date. 3. Patients who are under 18 years old at hospice admission. The most current data shows that in 2016 51.9% of Medicare Advantage (MA) beneficiaries utilized hospice care. There is currently no way for CMS to capture the necessary claims data to include MA beneficiaries in the measure calculation. We believe that leaving these patients out of the measure reduces its usefulness. Additionally, in hospice care there are various discharge codes depending on the reason that the patient is leaving service and the measure specifications include all of them. Patients may revoke service or be discharged or transferred because they have moved out of the area or gone for an extended stay with family members. Patients may be discharged because they (without knowledge of the hospice) admitted themselves to a hospital at which the hospice may not have a contract and cannot continue to treat the patient. Veterans may decide to be served at a VA facility, which requires discharge from hospice care. Patients may also be discharged because they are determined to be no longer be eligible for hospice services. Further, cause for discharge may vary widely depending on market and/or geographic factors. These factors have the potential to dramatically impact some hospices while having little to no impact on others in a different area of a state, region or the country. CMS should consider excluding certain types of live discharges and circumstances surrounding them, including discharges for cause, revocations, transfers, and discharges due to the patient moving out of the service. All of these are, in large part, beyond a hospice’s control. In its review of comments submitted to CMS on this measure, CMS addressed the ways it would intend to handle these types of discharges. Even with some of the risk adjustments CMS intends to make, it appears that CMS would retain a significant number of reasons for live discharge reflecting situations that are out of the hospice’s control and for which they could be penalized. This is especially true of transfer situations. In looking at this proposed measure, it is notable that there is not a consideration of whether the acute care a patient may seek after hospice care is aligned with the patient’s goals. We believe that measures assessing goal attainment and specifically whether a patient’s goals of care align with the care received are more meaningful and could be utilized for hospice performance improvement and consumer education much more efficiently and effectively than the proposed transitions of care measure. If the measure is used in the hospice quality reporting program it is critical that a dry run be implemented and results critically analyzed before any public reporting. If this measure is used for public reporting there must be a clear explanation of the measure, in layman’s terms, that accompanies the posting. MUC18- 131 Transfer of Health Information to Patient—PostAcute Care, and MUC18- 135 Transfer of Health Information to Provider—PostAcute Care In both of these measures under consideration, the assessment items used to record the data have not been finalized and thus are not available for review nor is a draft version showing how the measures might be revised in light of the feedback CMS received from its request for public comment. These are necessary for full consideration of the measure especially since many of the comments submitted by stakeholders on these measures were related to the data source (assessment items) directly. One of the assessment items in particular, Route of Transmission, is of particular concern. NAHC does not support including this question as part of the comprehensive assessment. There is no correlation between the route of transmission and quality of care provided by post-acute care providers and home health in particular. It is unclear why it is important for providers or the public to have this information or what might be gained from having the information . It cannot be assumed that one route is preferred above another, and therefore, reporting the route of transmission without context is not meaningful for utilization by providers in performance improvement or for patients/caregivers/consumers. In fact, there was disagreement within the Technical Expert Panel (TEP) convened by CMS on the route of transmission assessment item. The only exclusion for these measures is patients who died. In the comments provided to CMS when stakeholder input was solicited on this measure, NAHC recommended the exclusion of any patient from the measure calculation where the home health agency assessment data identifies that the HHA was not made of a transfer timely. NAHC is concerned that if untimely transfers are not accounted for in the measure calculation, the measure rate for HHAs could be artificially low. Unlike the facility-based providers, some portion of HHA patients and the providers to which they transfer might not receive a medication profile at transfer for reasons out of the home health agency’s control. This could have unintended consequences for HHAs when used as a cross setting measure with other post- acute care providers. The second of these measures, MUC18- 135, includes the transfer of medication information when a patient is being transferred to settings including: • Private home/ apartment (apt.), • Board/care, • Assisted living, • Group home, • Transitional living or • Home under care of organized home health service organization or hospice It is unclear as to why a home health agency would need to provide a medication profile to the patient, family and/or caregiver in a transfer to another home health service organization or hospice as the patient would continue to receive care by the other home health service organization or hospice and the medication profile would be shared with this provider as a matter of practice. Thank you for this opportunity to provide input on these measures under consideration. We recognize the MAP’s overall timeframe for reviewing these measures is tight and appreciate having the opportunity to provide feedback. However, the timeframe given for public commenting is limited to five business days which makes it somewhat difficult to review the measures in context and formulate comments. If there is any way in the future to extend this review period it would be much appreciated. Please do not hesitate to contact us if our comments require clarification in any way. Sincerely, Katie Wehri Katie Wehri Director, Home Care & Hospice Regulatory Affairs (Submitted by: National Association for Home Care & Hospice (NAHC))

      • Live discharges that are the result of a patient revoking his or her election of the hospice benefit, or moving out of the hospice’s service area, should not be included in the proposed measure. The Medicare hospice regulations are clear that “an individual or representative may revoke the individual’s election of hospice care at any time during an election period.” (42 CFR §418.28(a)) Despite counseling and recommendations from the hospice, patients continue to have a right to revert to the traditional Medicare benefit at any time. Their choosing to exercise that right should not be a direct reflection on the quality of care provided by the hospice. Similarly, when a patient is discharged after they choose to move outside a hospice’s service area, those discharges also should be excluded from the measure. Discharges from hospice followed by an inpatient hospital admission may occur for a variety of reasons, some of which may be related to the hospice’s quality and some of which may be due to factors beyond their control, such as the refusal of hospitals in their service area to contract with them for beds to provide General Inpatient Care (GIP). One way to focus the measure on factors closer to a hospice provider’s control would be to reduce from 7 days to 1 day the period during which an inpatient hospital admission, ED visit, or observation stay would be counted in the measure numerator. This approach still would not completely account for the contracting practices of the hospitals in a hospice’s service area. This issue underscores the point that the proposed measure is at best a crude measure of care quality because it will be next to impossible to adjust for all the factors that are beyond a hospice’s control. Hospices must carefully evaluate their patients’ clinical conditions when deciding whether to admit them and periodically thereafter to make sure they continue to meet the benefit’s eligibility criteria. Some patients’ conditions improve while they are receiving hospice care to the point where they no longer meet the eligibility criteria but are still severely ill and medically fragile. Our members’ experience is that a significant portion of their patients appear to be relatively stable, are therefore discharged from hospice for no longer meeting the eligibility criteria, and then die within a matter of a few weeks. Many of these patients would be captured in the 30-day post-discharge period of the current measure specifications, which does not seem to be a fair measure of the hospice’s quality of care. This is particularly true in the current regulatory environment, in which Medicare contractors’ erroneous interpretation that patients must be experiencing continuous decline in order to be hospice eligible is forcing live discharges from hospice that are not consistent with the intent or letter of the law or regulations. A shorter period, such as 7 or 14 days, to observe post-discharge deaths would still capture inappropriate discharges of medically unstable patients, while excluding patients who are discharged in relatively stable condition but still seriously ill and facing imminent end of life. Certain discharges from hospice to an inpatient hospital followed by death may be planned and in accordance with the patient’s plan of care. One of our member hospices is a preferred provider for the local Veterans Administration health system, and many patients referred by the VA are admitted to this hospice with a plan for the hospice agency to care for them at home for as long as possible and then to transfer them to the palliative care unit of a local inpatient VA facility for their final days. This would of course appear to Medicare as a live discharge followed by death within 30 days. We recommend excluding patients discharged to palliative care unit of an inpatient VA hospital so as not to penalize hospices who have a relationship with their local VAs and would be more likely to admit patients with this sort of plan for end of life. State CON laws can affect whether a hospice provider must discharge a patient who has been admitted to a nearby inpatient hospital that is outside of the hospice’s service area. We suggest exploring the impact of adding a binary (yes/no) variable to the risk adjustment algorithm reflecting the presence of a State CON law that includes hospice providers. The presence of a “Do Not Resuscitate” (DNR) code for a hospice patient is another variable beyond a hospice’s control that should be included in the risk adjustment methodology. All else being equal, a patient’s DNR code would affect a hospice’s rate of deaths within 30 days following discharge. It is our understanding that DNR codes are not included in Medicare claims data, but we urge RTI to investigate if other Medicare data sources that capture whether a beneficiary had a DNR code could be added to the measure’s risk adjustment formula. (Submitted by: National Partnership for Hospice Innovation)

      • NHPCO Comments: NHPCO shares the concern about hospices with higher rates of live discharges and higher rates of negative outcomes after live discharge. While we have concerns about live discharges, the measure should recognize that there will always be live discharges in hospice – either by patient choice to revoke or transfer or by a hospice-initiated discharge for patients whose condition has stabilized, have moved out of the hospice’s service area or for whom the discharge is for cause. As NHPCO commented on the draft measure specifications for this measure in April 2018, we continue to be concerned that there is no mention in the rationale or in the documentation provided with this MUC list that shares the measure’s intent to include all live discharges, regardless of reason. While the measure is targeting hospices with very high rates of live discharge, this broad-based, all reasons for live discharge inclusion may cause concern among providers about live-discharging patients when a live discharge is appropriate. Some language in the rationale or background on this measure must address that issue. The rationale states that ” [2] Measuring transitions among hospice patients and assessing outcomes following transitions from hospice care can therefore provide valuable information about hospices’ quality of care.” NHPCO’s ongoing concern is that by only using claims data, there will be no opportunity to assess the patient’s individual circumstances and reasons for live discharge. How can the hospice’s quality of care be determined by claims data and coded reasons for discharge? The exclusions list for this measure does not include patients who were discharged alive or transferred, receiving care continuously but from another hospice provider. Would this live discharge or transfer count as a discharge in the numerator? We continue to be concerned that this quality measure is derived from claims information only. The claims data will be able to determine the reason for the live discharge, but no other details about the care or the reasons for the discharge. NHPCO strongly urges NQF to investigate additional ways to gather information on live discharge and subsequent Medicare services. (Submitted by: National Hospice and Palliative Care Organization)

      • This measure will provide more information to examine outcomes post hospice discharge, and could inform improvements in care and future policy changes. (Submitted by: Center to Advance Palliative Care)

      • We support this measure although urge NQF and CMS to find further ways to dimensionalize why some patients may justifiable leave hospice care before death. (Submitted by: CTAC)

      Transfer of Health Information to Provider—Post-Acute Care (Program: Home Health Quality Reporting Program; MUC ID: MUC2018-131)
      • VIA: http://www.qualityforum.org/map/ December 6, 2018 Public Comment 2018 Measures Under Consideration Submitted via: Since 1982, the National Association for Home Care & Hospice (NAHC) has been the leading association representing the interests of hospices, home health, and home care providers across the nation, including the home caregiving staff and the patients and families they serve. Our members are providers of all sizes and types -- from small rural agencies to large national companies -- and include government-based providers, nonprofit voluntary hospices, privately-owned companies and public corporations. As such, we welcome the opportunity to comment on the CMS List of Measures Under Consideration for December 1, 2018. We are commenting on the following three measures: MUC18- 101 Transitions from Hospice Care, Followed by Death or Acute Care MUC18- 131 Transfer of Health Information to Patient—PostAcute Care MUC18- 135 Transfer of Health Information to Provider—PostAcute Care MUC18- 101 Transitions from Hospice Care, Followed by Death or Acute Care As we commented to CMS directly in 2018, we believe this measure falls short of providing a direct indicator of quality of care, has significant potential unintended consequences the least of which is confusion about a hospice’s performance amongst consumers. This raises concern, particularly relative to use of this measure for public reporting. We appreciate and understand the intent of this measure which is to assess negative outcomes following hospice live discharge, including acute care use shortly after discharge, as these outcomes represent potentially burdensome transitions to patients and families. We also appreciate the considerable expansion by CMS of the risk adjustment factors, based on previous public comment, to include a patient’s prior use of acute care services, social risk factors, setting of care while receiving hospice care, etc. We further appreciate that CMS would potentially plan a dry run of this measure, as indicated in its public comment summary report for this measure (August 2018), to determine if the measure is appropriate for public reporting. There is considerable potential for misunderstanding of this measure, and consequent unintended negative consequences. This was emphasized in the comments CMS received, and in its response, CMS stated “Finally, additional measure testing and refinement, including a potential measure dry run will aim to further address the potential unintended consequences of the measure.” We believe this additional measure testing and refinement is crucial to making the measure meaningful to providers and for providers to utilize the measure to inform improvement actions. The current measure specifications exclude the following types of patients: 1. Patients not continuously enrolled in Part A Medicare FFS in the 12 months prior to the hospice admission date, during the hospice stay, or at least 7 days following the hospice discharge date 2. Patients enrolled in Medicare Advantage in the 12 months prior to the hospice admission date, during the hospice stay, or in the 7 days following the hospice discharge date. 3. Patients who are under 18 years old at hospice admission. The most current data shows that in 2016 51.9% of Medicare Advantage (MA) beneficiaries utilized hospice care. There is currently no way for CMS to capture the necessary claims data to include MA beneficiaries in the measure calculation. We believe that leaving these patients out of the measure reduces its usefulness. Additionally, in hospice care there are various discharge codes depending on the reason that the patient is leaving service and the measure specifications include all of them. Patients may revoke service or be discharged or transferred because they have moved out of the area or gone for an extended stay with family members. Patients may be discharged because they (without knowledge of the hospice) admitted themselves to a hospital at which the hospice may not have a contract and cannot continue to treat the patient. Veterans may decide to be served at a VA facility, which requires discharge from hospice care. Patients may also be discharged because they are determined to be no longer be eligible for hospice services. Further, cause for discharge may vary widely depending on market and/or geographic factors. These factors have the potential to dramatically impact some hospices while having little to no impact on others in a different area of a state, region or the country. CMS should consider excluding certain types of live discharges and circumstances surrounding them, including discharges for cause, revocations, transfers, and discharges due to the patient moving out of the service. All of these are, in large part, beyond a hospice’s control. In its review of comments submitted to CMS on this measure, CMS addressed the ways it would intend to handle these types of discharges. Even with some of the risk adjustments CMS intends to make, it appears that CMS would retain a significant number of reasons for live discharge reflecting situations that are out of the hospice’s control and for which they could be penalized. This is especially true of transfer situations. In looking at this proposed measure, it is notable that there is not a consideration of whether the acute care a patient may seek after hospice care is aligned with the patient’s goals. We believe that measures assessing goal attainment and specifically whether a patient’s goals of care align with the care received are more meaningful and could be utilized for hospice performance improvement and consumer education much more efficiently and effectively than the proposed transitions of care measure. If the measure is used in the hospice quality reporting program it is critical that a dry run be implemented and results critically analyzed before any public reporting. If this measure is used for public reporting there must be a clear explanation of the measure, in layman’s terms, that accompanies the posting. MUC18- 131 Transfer of Health Information to Patient—PostAcute Care, and MUC18- 135 Transfer of Health Information to Provider—PostAcute Care In both of these measures under consideration, the assessment items used to record the data have not been finalized and thus are not available for review nor is a draft version showing how the measures might be revised in light of the feedback CMS received from its request for public comment. These are necessary for full consideration of the measure especially since many of the comments submitted by stakeholders on these measures were related to the data source (assessment items) directly. One of the assessment items in particular, Route of Transmission, is of particular concern. NAHC does not support including this question as part of the comprehensive assessment. There is no correlation between the route of transmission and quality of care provided by post-acute care providers and home health in particular. It is unclear why it is important for providers or the public to have this information or what might be gained from having the information . It cannot be assumed that one route is preferred above another, and therefore, reporting the route of transmission without context is not meaningful for utilization by providers in performance improvement or for patients/caregivers/consumers. In fact, there was disagreement within the Technical Expert Panel (TEP) convened by CMS on the route of transmission assessment item. The only exclusion for these measures is patients who died. In the comments provided to CMS when stakeholder input was solicited on this measure, NAHC recommended the exclusion of any patient from the measure calculation where the home health agency assessment data identifies that the HHA was not made of a transfer timely. NAHC is concerned that if untimely transfers are not accounted for in the measure calculation, the measure rate for HHAs could be artificially low. Unlike the facility-based providers, some portion of HHA patients and the providers to which they transfer might not receive a medication profile at transfer for reasons out of the home health agency’s control. This could have unintended consequences for HHAs when used as a cross setting measure with other post- acute care providers. The second of these measures, MUC18- 135, includes the transfer of medication information when a patient is being transferred to settings including: • Private home/ apartment (apt.), • Board/care, • Assisted living, • Group home, • Transitional living or • Home under care of organized home health service organization or hospice It is unclear as to why a home health agency would need to provide a medication profile to the patient, family and/or caregiver in a transfer to another home health service organization or hospice as the patient would continue to receive care by the other home health service organization or hospice and the medication profile would be shared with this provider as a matter of practice. Thank you for this opportunity to provide input on these measures under consideration. We recognize the MAP’s overall timeframe for reviewing these measures is tight and appreciate having the opportunity to provide feedback. However, the timeframe given for public commenting is limited to five business days which makes it somewhat difficult to review the measures in context and formulate comments. If there is any way in the future to extend this review period it would be much appreciated. Please do not hesitate to contact us if our comments require clarification in any way. Sincerely, Katie Wehri Katie Wehri Director, Home Care & Hospice Regulatory Affairs (Submitted by: National Association for Home Care & Hospice (NAHC))

      • ARN supports the measures under consideration for Post Acute care settings (Home health, SNF, LTCH and IRF) with regard to medication reconciliation and sharing patient health information to 1) providers and 2) patients, families and / or caregivers. We believe these measures demonstrate a commitment to quality thereby ensuring that important medication information is shared and communicated at transitions. Accurate medication profile information helps keep a patient medication compliant, thereby potentially reducing 30-day re-admission rates. (Submitted by: Association of Rehabilitation Nurses)

      • Confirmed transfer of a reconciled medication list to providers is a critical component to improving care for people with serious illness; this is a good measure to include in this quality reporting program. (Submitted by: Center to Advance Palliative Care)

      • NHPCO Comments: NHPCO supports this measure as a patient safety and quality of care issue, especially for seriously ill individuals. (Submitted by: National Hospice and Palliative Care Organization)

      • The Federation of American Hospitals notes that this measure includes language requiring a “reconciled medication list”, which differs from the draft specification released for comment earlier this year. FAH requests that information on what constitutes a “reconciled medication list” be provided during the MAP review to enable a thorough assessment of whether these refinements have made data collection more feasible and less subjective. (Submitted by: Federation of American Hospitals)

      • These comments apply to MUC 18-131, 132, 133, 135, 136, 138, 139, 141. AOTA appreciates the opportunity to comment on the Transfer of Health Information PAC measures. We agree that a reconciled medication list is a logical first measure to implement in the transfer of health information in these settings. (Submitted by: American Occupational Therapy Association)

      • We request an operationalization or definition of the phrase “at the time of discharge/transfer.” This applies to the other 'Transfer' measures #131-136. (Submitted by: National Assn for Behavioral Healthcare)

      Transfer of Health Information to Provider—Post-Acute Care (Program: Inpatient Rehabilitation Facility Quality Reporting Program; MUC ID: MUC2018-132)
      • AMRPA appreciates the opportunities to provide input to the NQF Measures Application Partnership regarding the Transfer of Health Information measures under consideration for the Inpatient Rehabilitation Facility Quality Reporting Program (IRF QRP) in the 2019 pre-rulemaking cycle. AMRPA is the national trade association representing more than 600 freestanding inpatient rehabilitation hospitals and rehabilitation units of general hospitals (referred to as inpatient rehabilitation facilities (IRFs) by Medicare) and outpatient rehabilitation service providers. Inpatient rehabilitation hospitals and units (IRH/Us) provide hospital-level care, which is significantly different in intensity, capacity, and outcomes from care provided in non-hospital post-acute settings. AMRPA remains supportive of the intent of the Transfer of Health Information measures which fulfill a domain required by the IMPACT Act. It it is critical to ensure that clinically relevant, valuable, and actionable patient information is transferred to the patient/family or to a downstream provider at discharge from PAC. Nonetheless, AMRPA is unable to fully support the quality measures because stakeholders have not been afforded an opportunity to the full extent of the measures; specifically, the technical specifications for these measures as they are characterized in the 2019 MUC List. CMS appears to have altered the scope of these measures since draft specifications were last made public in spring 2018. At that time, these measures were titled Transfer of Info: Medication Profile and the specification report proposed a list of patient data items for providers to report. However, in this 2019 MUC list, the measures description has been revised and is as follows: “For this measure, the timely transfer of health information specifically assesses for the transfer of the patient’s current reconciled medication list.” There is minimal information beyond that. Without seeing details as to what constitutes a “reconciled medication list” or how CMS would implement reporting, we are unable to comment on how the measures would add value to the IRF QRP and improve patient outcomes, or assess if measure benefits would outweigh the burden of data collection/reporting. In short, we are not able to substantively respond to the questions NQF is asking stakeholders. We respectfully request CMS provide the technical specifications for both Transfer of Health Information Measures Under Considerations for PAC so that stakeholders can review the measures in full and provide considered and meaningful input. AMRPA commented on the TOH: Medication Profile draft specifications this past spring. AMRPA’s comments reflected feedback from our Quality Committee with input from pharmacists, administrators, physicians and other clinicians at inpatient rehabilitation hospitals and units. Our members agree that the accurate and successful transfer of essential medication information at PAC discharge/transfer is critical to ensuring that patient safety and quality of care are not compromised once a patient leaves a particular setting. While we supported the measures’ intent, at that time, many aspects of the measures are yet to be specified such as: the data elements required for reporting, the process by which they would be reported, whether changes need to be made to the mandatory IRF Patient Assessment Instrument (IRF PAI) to accommodate measure reporting, and how CMS would ensure measure validity for these process-based measures, among other questions. As CMS continues to develop the Transfer of Health Information measures, we urge it to do so in a practical and minimally burdensome manner that adds value beyond rehabilitation hospitals’ current medication reconciliation and/or discharge planning practices. This would be consistent with CMS’ Patients over Paperwork and Meaningful Measures initiatives which aim to reduce providers’ administrative burden, and specifically with regard to burden from quality measures. (Submitted by: American Medical Rehabilitation Providers Association (AMRPA))

      • ARN supports the measures under consideration for Post Acute care settings (Home health, SNF, LTCH and IRF) with regard to medication reconciliation and sharing patient health information to 1) providers and 2) patients, families and / or caregivers. We believe these measures demonstrate a commitment to quality thereby ensuring that important medication information is shared and communicated at transitions. Accurate medication profile information helps keep a patient medication compliant, thereby potentially reducing 30-day re-admission rates. (Submitted by: Association of Rehabilitation Nurses)

      • Confirmed transfer of a reconciled medication list to providers is a critical component to improving care for people with serious illness; this is a good measure to include in this quality reporting program. (Submitted by: Center to Advance Palliative Care)

      • NHPCO Comments: NHPCO supports this measure as a patient safety and quality of care issue, especially for seriously ill individuals. (Submitted by: National Hospice and Palliative Care Organization)

      • The Federation of American Hospitals notes that this measure includes language requiring a “reconciled medication list”, which differs from the draft specification released for comment earlier this year. FAH requests that information on what constitutes a “reconciled medication list” be provided during the MAP review to enable a thorough assessment of whether these refinements have made data collection more feasible and less subjective. (Submitted by: Federation of American Hospitals)

      • We are unable to comment on MUC2018-132 Transfer of Health Information to Provider without measure specifications. The 2018 Measures Under Consideration List, Program Specific Measure Needs and Priorities (May 29, 2018) states under section 3. Candidate Measure Submission Guidance, "In an effort to provide a more meaningful List of Measures under Consideration, CMS included only measures that contain adequate specifications." However, for measure 2018-132, only a numerator and denominator were supplied on the MUC. While a similar transfer of health information measure and measure specifications were released for public comment in the spring of 2018, CMS has noted the measure on the MUC list has been modified and does not therefore use the same specifications. Given the potential of this measure to be comprehensive in scope, without understanding the elements included in the numerator, it is not possible to meaningfully comment on the measure proposed on the MUC list. Since the measure is not defined beyond a numerator and denominator, we cannot support its consideration into the IRF QRP. (Submitted by: Encompass Health)

      • We support this measure although find the name confusion and so recommend renaming it to: be “Transfer of a “reconciled” medication list” from hospital to post-hospital care provider. We also suggest it would be useful to also include/transfer a statement about the likely course and the patient’s situation with regard to social supports and personal care. (Submitted by: CTAC)

      Transfer of Health Information to Provider—Post-Acute Care (Program: Long-Term Care Hospital Quality Reporting Program; MUC ID: MUC2018-133)
      • ARN supports the measures under consideration for Post Acute care settings (Home health, SNF, LTCH and IRF) with regard to medication reconciliation and sharing patient health information to 1) providers and 2) patients, families and / or caregivers. We believe these measures demonstrate a commitment to quality thereby ensuring that important medication information is shared and communicated at transitions. Accurate medication profile information helps keep a patient medication compliant, thereby potentially reducing 30-day re-admission rates. (Submitted by: Association of Rehabilitation Nurses)

      • Confirmed transfer of a reconciled medication list to providers is a critical component to improving care for people with serious illness; this is a good measure to include in this quality reporting program. (Submitted by: Center to Advance Palliative Care)

      • NHPCO Comments: NHPCO supports this measure as a patient safety and quality of care issue, especially for seriously ill individuals. (Submitted by: National Hospice and Palliative Care Organization)

      • The Federation of American Hospitals notes that this measure includes language requiring a “reconciled medication list”, which differs from the draft specification released for comment earlier this year. FAH requests that information on what constitutes a “reconciled medication list” be provided during the MAP review to enable a thorough assessment of whether these refinements have made data collection more feasible and less subjective. (Submitted by: Federation of American Hospitals)

      • We support this measure although find the name confusion and so recommend renaming it to: be “Transfer of a “reconciled” medication list” from hospital to post-hospital care provider. We also suggest it would be useful to also include/transfer a statement about the likely course and the patient’s situation with regard to social supports and personal care. (Submitted by: CTAC)

      Transfer of Health Information to Patient—Post-Acute Care (Program: Home Health Quality Reporting Program; MUC ID: MUC2018-135)
      • VIA: http://www.qualityforum.org/map/ December 6, 2018 Public Comment 2018 Measures Under Consideration Submitted via: Since 1982, the National Association for Home Care & Hospice (NAHC) has been the leading association representing the interests of hospices, home health, and home care providers across the nation, including the home caregiving staff and the patients and families they serve. Our members are providers of all sizes and types -- from small rural agencies to large national companies -- and include government-based providers, nonprofit voluntary hospices, privately-owned companies and public corporations. As such, we welcome the opportunity to comment on the CMS List of Measures Under Consideration for December 1, 2018. We are commenting on the following three measures: MUC18- 101 Transitions from Hospice Care, Followed by Death or Acute Care MUC18- 131 Transfer of Health Information to Patient—PostAcute Care MUC18- 135 Transfer of Health Information to Provider—PostAcute Care MUC18- 101 Transitions from Hospice Care, Followed by Death or Acute Care As we commented to CMS directly in 2018, we believe this measure falls short of providing a direct indicator of quality of care, has significant potential unintended consequences the least of which is confusion about a hospice’s performance amongst consumers. This raises concern, particularly relative to use of this measure for public reporting. We appreciate and understand the intent of this measure which is to assess negative outcomes following hospice live discharge, including acute care use shortly after discharge, as these outcomes represent potentially burdensome transitions to patients and families. We also appreciate the considerable expansion by CMS of the risk adjustment factors, based on previous public comment, to include a patient’s prior use of acute care services, social risk factors, setting of care while receiving hospice care, etc. We further appreciate that CMS would potentially plan a dry run of this measure, as indicated in its public comment summary report for this measure (August 2018), to determine if the measure is appropriate for public reporting. There is considerable potential for misunderstanding of this measure, and consequent unintended negative consequences. This was emphasized in the comments CMS received, and in its response, CMS stated “Finally, additional measure testing and refinement, including a potential measure dry run will aim to further address the potential unintended consequences of the measure.” We believe this additional measure testing and refinement is crucial to making the measure meaningful to providers and for providers to utilize the measure to inform improvement actions. The current measure specifications exclude the following types of patients: 1. Patients not continuously enrolled in Part A Medicare FFS in the 12 months prior to the hospice admission date, during the hospice stay, or at least 7 days following the hospice discharge date 2. Patients enrolled in Medicare Advantage in the 12 months prior to the hospice admission date, during the hospice stay, or in the 7 days following the hospice discharge date. 3. Patients who are under 18 years old at hospice admission. The most current data shows that in 2016 51.9% of Medicare Advantage (MA) beneficiaries utilized hospice care. There is currently no way for CMS to capture the necessary claims data to include MA beneficiaries in the measure calculation. We believe that leaving these patients out of the measure reduces its usefulness. Additionally, in hospice care there are various discharge codes depending on the reason that the patient is leaving service and the measure specifications include all of them. Patients may revoke service or be discharged or transferred because they have moved out of the area or gone for an extended stay with family members. Patients may be discharged because they (without knowledge of the hospice) admitted themselves to a hospital at which the hospice may not have a contract and cannot continue to treat the patient. Veterans may decide to be served at a VA facility, which requires discharge from hospice care. Patients may also be discharged because they are determined to be no longer be eligible for hospice services. Further, cause for discharge may vary widely depending on market and/or geographic factors. These factors have the potential to dramatically impact some hospices while having little to no impact on others in a different area of a state, region or the country. CMS should consider excluding certain types of live discharges and circumstances surrounding them, including discharges for cause, revocations, transfers, and discharges due to the patient moving out of the service. All of these are, in large part, beyond a hospice’s control. In its review of comments submitted to CMS on this measure, CMS addressed the ways it would intend to handle these types of discharges. Even with some of the risk adjustments CMS intends to make, it appears that CMS would retain a significant number of reasons for live discharge reflecting situations that are out of the hospice’s control and for which they could be penalized. This is especially true of transfer situations. In looking at this proposed measure, it is notable that there is not a consideration of whether the acute care a patient may seek after hospice care is aligned with the patient’s goals. We believe that measures assessing goal attainment and specifically whether a patient’s goals of care align with the care received are more meaningful and could be utilized for hospice performance improvement and consumer education much more efficiently and effectively than the proposed transitions of care measure. If the measure is used in the hospice quality reporting program it is critical that a dry run be implemented and results critically analyzed before any public reporting. If this measure is used for public reporting there must be a clear explanation of the measure, in layman’s terms, that accompanies the posting. MUC18- 131 Transfer of Health Information to Patient—PostAcute Care, and MUC18- 135 Transfer of Health Information to Provider—PostAcute Care In both of these measures under consideration, the assessment items used to record the data have not been finalized and thus are not available for review nor is a draft version showing how the measures might be revised in light of the feedback CMS received from its request for public comment. These are necessary for full consideration of the measure especially since many of the comments submitted by stakeholders on these measures were related to the data source (assessment items) directly. One of the assessment items in particular, Route of Transmission, is of particular concern. NAHC does not support including this question as part of the comprehensive assessment. There is no correlation between the route of transmission and quality of care provided by post-acute care providers and home health in particular. It is unclear why it is important for providers or the public to have this information or what might be gained from having the information . It cannot be assumed that one route is preferred above another, and therefore, reporting the route of transmission without context is not meaningful for utilization by providers in performance improvement or for patients/caregivers/consumers. In fact, there was disagreement within the Technical Expert Panel (TEP) convened by CMS on the route of transmission assessment item. The only exclusion for these measures is patients who died. In the comments provided to CMS when stakeholder input was solicited on this measure, NAHC recommended the exclusion of any patient from the measure calculation where the home health agency assessment data identifies that the HHA was not made of a transfer timely. NAHC is concerned that if untimely transfers are not accounted for in the measure calculation, the measure rate for HHAs could be artificially low. Unlike the facility-based providers, some portion of HHA patients and the providers to which they transfer might not receive a medication profile at transfer for reasons out of the home health agency’s control. This could have unintended consequences for HHAs when used as a cross setting measure with other post- acute care providers. The second of these measures, MUC18- 135, includes the transfer of medication information when a patient is being transferred to settings including: • Private home/ apartment (apt.), • Board/care, • Assisted living, • Group home, • Transitional living or • Home under care of organized home health service organization or hospice It is unclear as to why a home health agency would need to provide a medication profile to the patient, family and/or caregiver in a transfer to another home health service organization or hospice as the patient would continue to receive care by the other home health service organization or hospice and the medication profile would be shared with this provider as a matter of practice. Thank you for this opportunity to provide input on these measures under consideration. We recognize the MAP’s overall timeframe for reviewing these measures is tight and appreciate having the opportunity to provide feedback. However, the timeframe given for public commenting is limited to five business days which makes it somewhat difficult to review the measures in context and formulate comments. If there is any way in the future to extend this review period it would be much appreciated. Please do not hesitate to contact us if our comments require clarification in any way. Sincerely, Katie Wehri Katie Wehri Director, Home Care & Hospice Regulatory Affairs (Submitted by: National Association for Home Care & Hospice)

      • ARN supports the measures under consideration for Post Acute care settings (Home health, SNF, LTCH and IRF) with regard to medication reconciliation and sharing patient health information to 1) providers and 2) patients, families and / or caregivers. We believe these measures demonstrate a commitment to quality thereby ensuring that important medication information is shared and communicated at transitions. Accurate medication profile information helps keep a patient medication compliant, thereby potentially reducing 30-day re-admission rates. (Submitted by: Association of Rehabilitation Nurses)

      • Confirmed provision of a reconciled medication list to the patient, family, and/or caregiver is a critical component to improving care for people with serious illness, and can help empower them to better manage their own care. This is a good measure to include in this quality reporting program. (Submitted by: Center to Advance Palliative Care)

      • NHPCO Comments: NHPCO supports this measure as a patient safety and quality of care issue, especially for seriously ill individuals. (Submitted by: National Hospice and Palliative Care Organization)

      • The Federation of American Hospitals notes that this measure includes language requiring a “reconciled medication list”, which differs from the draft specification released for comment earlier this year. FAH requests that information on what constitutes a “reconciled medication list” be provided during the MAP review to enable a thorough assessment of whether these refinements have made data collection more feasible and less subjective. (Submitted by: Federation of American Hospitals)

      • We support this measure although recommend renaming it to: be “Transfer of a “reconciled” medication list” from hospital to post-hospital care provider. We also suggest it would be useful to also include/transfer a statement about the likely course and the patient’s situation with regard to social supports and personal care. (Submitted by: CTAC)

      Transfer of Health Information to Provider—Post-Acute Care (Program: Skilled Nursing Facility Quality Reporting Program; MUC ID: MUC2018-136)
      • ARN supports the measures under consideration for Post Acute care settings (Home health, SNF, LTCH and IRF) with regard to medication reconciliation and sharing patient health information to 1) providers and 2) patients, families and / or caregivers. We believe these measures demonstrate a commitment to quality thereby ensuring that important medication information is shared and communicated at transitions. Accurate medication profile information helps keep a patient medication compliant, thereby potentially reducing 30-day re-admission rates. (Submitted by: Association of Rehabilitation Nurses)

      • Confirmed transfer of a reconciled medication list to providers is a critical component to improving care for people with serious illness; this is a good measure to include in this quality reporting program. (Submitted by: Center to Advance Palliative Care)

      • NHPCO Comments: NHPCO supports this measure as a patient safety and quality of care issue, especially for seriously ill individuals. (Submitted by: National Hospice and Palliative Care Organization)

      • We support this measure although find the name confusion and so recommend renaming it to: be “Transfer of a “reconciled” medication list” from hospital to post-hospital care provider. We also suggest it would be useful to also include/transfer a statement about the likely course and the patient’s situation with regard to social supports and personal care. (Submitted by: CTAC)

      Transfer of Health Information to Patient—Post-Acute Care (Program: Skilled Nursing Facility Quality Reporting Program; MUC ID: MUC2018-138)
      • ARN supports the measures under consideration for Post Acute care settings (Home health, SNF, LTCH and IRF) with regard to medication reconciliation and sharing patient health information to 1) providers and 2) patients, families and / or caregivers. We believe these measures demonstrate a commitment to quality thereby ensuring that important medication information is shared and communicated at transitions. Accurate medication profile information helps keep a patient medication compliant, thereby potentially reducing 30-day re-admission rates. (Submitted by: Association of Rehabilitation Nurses)

      • Confirmed provision of a reconciled medication list to the patient, family, and/or caregiver is a critical component to improving care for people with serious illness, and can help empower them to better manage their own care. This is a good measure to include in this quality reporting program. (Submitted by: Center to Advance Palliative Care)

      • NHPCO Comments: NHPCO supports this measure as a patient safety and quality of care issue, especially for seriously ill individuals. (Submitted by: National Hospice and Palliative Care Organization)

      • The Federation of American Hospitals notes that this measure includes language requiring a “reconciled medication list”, which differs from the draft specification released for comment earlier this year. FAH requests that information on what constitutes a “reconciled medication list” be provided during the MAP review to enable a thorough assessment of whether these refinements have made data collection more feasible and less subjective. (Submitted by: Federation of American Hospitals)

      • These comments apply to MUC 18-131, 132, 133, 135, 136, 138, 139, 141. AOTA appreciates the opportunity to comment on the Transfer of Health Information PAC measures. We agree that a reconciled medication list is a logical first measure to implement in the transfer of health information in these settings. (Submitted by: American Occupational Therapy Association)

      • We support this measure although recommend renaming it to: be “Transfer of a “reconciled” medication list” from hospital to post-hospital care provider. We also suggest it would be useful to also include/transfer a statement about the likely course and the patient’s situation with regard to social supports and personal care. (Submitted by: CTAC)

      Transfer of Health Information to Patient—Post-Acute Care (Program: Inpatient Rehabilitation Facility Quality Reporting Program; MUC ID: MUC2018-139)
      • AMRPA appreciates the opportunities to provide input to the NQF Measures Application Partnership regarding the Transfer of Health Information measures under consideration for the Inpatient Rehabilitation Facility Quality Reporting Program (IRF QRP) in the 2019 pre-rulemaking cycle. AMRPA is the national trade association representing more than 600 freestanding inpatient rehabilitation hospitals and rehabilitation units of general hospitals (referred to as inpatient rehabilitation facilities (IRFs) by Medicare) and outpatient rehabilitation service providers. Inpatient rehabilitation hospitals and units (IRH/Us) provide hospital-level care, which is significantly different in intensity, capacity, and outcomes from care provided in non-hospital post-acute settings. AMRPA remains supportive of the intent of the Transfer of Health Information measures which fulfill a domain required by the IMPACT Act. It it is critical to ensure that clinically relevant, valuable, and actionable patient information is transferred to the patient/family or to a downstream provider at discharge from PAC. Nonetheless, AMRPA is unable to fully support the quality measures because stakeholders have not been afforded an opportunity to the full extent of the measures; specifically, the technical specifications for these measures as they are characterized in the 2019 MUC List. CMS appears to have altered the scope of these measures since draft specifications were last made public in spring 2018. At that time, these measures were titled Transfer of Info: Medication Profile and the specification report proposed a list of patient data items for providers to report. However, in this 2019 MUC list, the measures description has been revised and is as follows: “For this measure, the timely transfer of health information specifically assesses for the transfer of the patient’s current reconciled medication list.” There is minimal information beyond that. Without seeing details as to what constitutes a “reconciled medication list” or how CMS would implement reporting, we are unable to comment on how the measures would add value to the IRF QRP and improve patient outcomes, or assess if measure benefits would outweigh the burden of data collection/reporting. In short, we are not able to substantively respond to the questions NQF is asking stakeholders. We respectfully request CMS provide the technical specifications for both Transfer of Health Information Measures Under Considerations for PAC so that stakeholders can review the measures in full and provide considered and meaningful input. AMRPA commented on the TOH: Medication Profile draft specifications this past spring. AMRPA’s comments reflected feedback from our Quality Committee with input from pharmacists, administrators, physicians and other clinicians at inpatient rehabilitation hospitals and units. Our members agree that the accurate and successful transfer of essential medication information at PAC discharge/transfer is critical to ensuring that patient safety and quality of care are not compromised once a patient leaves a particular setting. While we supported the measures’ intent, at that time, many aspects of the measures are yet to be specified such as: the data elements required for reporting, the process by which they would be reported, whether changes need to be made to the mandatory IRF Patient Assessment Instrument (IRF PAI) to accommodate measure reporting, and how CMS would ensure measure validity for these process-based measures, among other questions. As CMS continues to develop the Transfer of Health Information measures, we urge it to do so in a practical and minimally burdensome manner that adds value beyond rehabilitation hospitals’ current medication reconciliation and/or discharge planning practices. This would be consistent with CMS’ Patients over Paperwork and Meaningful Measures initiatives which aim to reduce providers’ administrative burden, and specifically with regard to burden from quality measures. (Submitted by: American Medical Rehabilitation Providers Association (AMRPA))

      • ARN supports the measures under consideration for Post Acute care settings (Home health, SNF, LTCH and IRF) with regard to medication reconciliation and sharing patient health information to 1) providers and 2) patients, families and / or caregivers. We believe these measures demonstrate a commitment to quality thereby ensuring that important medication information is shared and communicated at transitions. Accurate medication profile information helps keep a patient medication compliant, thereby potentially reducing 30-day re-admission rates. (Submitted by: Association of Rehabilitation Nurses)

      • Confirmed provision of a reconciled medication list to the patient, family, and/or caregiver is a critical component to improving care for people with serious illness, and can help empower them to better manage their own care. This is a good measure to include in this quality reporting program. (Submitted by: Center to Advance Palliative Care)

      • NHPCO Comments: NHPCO supports this measure as a patient safety and quality of care issue, especially for seriously ill individuals. (Submitted by: National Hospice and Palliative Care Organization)

      • We are unable to comment on MUC2018-132 Transfer of Health Information to Patient without measure specifications. The 2018 Measures Under Consideration List, Program Specific Measure Needs and Priorities (May 29, 2018) states under section 3. Candidate Measure Submission Guidance, "In an effort to provide a more meaningful List of Measures under Consideration, CMS included only measures that contain adequate specifications." However, for measure 2018-139, only a numerator and denominator were supplied on the MUC. While a similar transfer of health information measure and measure specifications were released for public comment in the spring of 2018, CMS has noted the measure on the MUC list has been modified and does not reflect those measure specifications. Given the potential of this measure to be comprehensive in scope, without understanding the elements included in the numerator, it is not possible to meaningfully comment on the measure proposed on the MUC list. Since the measure is not defined, we cannot support its consideration into the IRF QRP. (Submitted by: Encompass Health)

      • We support this measure although recommend renaming it to: be “Transfer of a “reconciled” medication list” from hospital to post-hospital care provider. We also suggest it would be useful to also include/transfer a statement about the likely course and the patient’s situation with regard to social supports and personal care. (Submitted by: CTAC)

      Transfer of Health Information to Patient—Post-Acute Care (Program: Long-Term Care Hospital Quality Reporting Program; MUC ID: MUC2018-141)
      • ARN supports the measures under consideration for Post Acute care settings (Home health, SNF, LTCH and IRF) with regard to medication reconciliation and sharing patient health information to 1) providers and 2) patients, families and / or caregivers. We believe these measures demonstrate a commitment to quality thereby ensuring that important medication information is shared and communicated at transitions. Accurate medication profile information helps keep a patient medication compliant, thereby potentially reducing 30-day re-admission rates. (Submitted by: Association of Rehabilitation Nurses)

      • Confirmed provision of a reconciled medication list to the patient, family, and/or caregiver is a critical component to improving care for people with serious illness, and can help empower them to better manage their own care. This is a good measure to include in this quality reporting program. (Submitted by: Center to Advance Palliative Care)

      • NHPCO Comments: NHPCO supports this measure as a patient safety and quality of care issue, especially for seriously ill individuals. (Submitted by: National Hospice and Palliative Care Organization)

      • The Federation of American Hospitals notes that this measure includes language requiring a “reconciled medication list”, which differs from the draft specification released for comment earlier this year. FAH requests that information on what constitutes a “reconciled medication list” be provided during the MAP review to enable a thorough assessment of whether these refinements have made data collection more feasible and less subjective. (Submitted by: Federation of American Hospitals)

      • Commenter did not submit written comments (Submitted by: CTAC)


      Appendix D: Instructions and Help

      If you have any problems navigating the discussion guide, please contact us at: mappacltc@qualityforum.org

      Navigating the Discussion Guide

      • How do I get back to the section I was just looking at?
        The easiest way is to use the back button on your browser. Other options are using your backspace button (which works for many browsers on laptops), or using the permanent links at the upper right hand corner of the discussion guide. But the back button is the best choice in most situations.

      • Can I print the discussion guide out?
        You can, but we don't recommend it. Besides using a lot of paper (probably a couple hundred pages at least), you'll lose all the links that allow you to move around the document. For instance, if you're scrolling through the agenda and want to see more information about a particular measure, the electronic format will allow you to click a link, read more, and then bo back. If you're on paper, there will be a lot of flipping through paper.

      • If I can't print this out, how can I read it on the plane?
        Although the Discussion Guide opens in a web browser, it does not require an internet connection if you have downloaded and saved the HTML file to your hard drive.

      • How do I know that I'm looking at the most recent version?
        At the top left corner of the discussion guide is a version number. At the beginning of the in person meetings, the NQF staff will ask everyone to load the most recent discussion guide version and will check that everyone has the same version loaded.

      • What electronic devices can I use to view the discussion guide?
        We tried to make this as universal as possible, so it should work on your laptop (PC, Mac, Linux), your tablet (iPad, Android), or your phone (iPhone, Android). It should also work on many types of browsers (IE, Firefox, Chrome, Safari, Opera, Dolphin,....). Please let us know if you have any problems, and we'll troubleshoot with you (and improve the discussion guide for the next go around).

      • Why do I see weird characters in some places?
        Because we're joining data from many different sources, we do find some technical challenges. This generally shows up as strange characters--extra question marks, accented characters, or otherwise unusual items. We've been able to fix many of these problems, but not all. We ask that you bear with us as we improve this over time!

      Content

      • What is included in the discussion guide?
        There are four sections within this document:
        • Agenda, with summaries of each measure under consideration
        • Full information about each measure, including its specifications, preliminary analysis of how this measure can advance the program's goals, and the rationale by HHS for being included in the list
        • Summaries for each federal health program being considered
        • Public comments that have been received to date (Note that the discussion guide may be released before the public comment period is finished, in which case there will just be a placeholder for where comments will go)

      • How are the meeting discussions organized?
        The meeting sessions are organized around consent calendars, which are groups of measures being considered for a particular program or groups of measures for a particular condition or topic area. For each measure being discussed, this document will show you the description, the public comments (if any), the summary of the preliminary analysis, and the result of the preliminary analysis algorithm.

      Appendix E: Instructions for Joining the Meeting Remotely

      Remote Participation Instructions:

      Streaming Audio Online
      • Direct your web browser to: http://nqf.commpartners.com/.
      • Under “Enter a Meeting” type in the meeting number for Day 1: 942049
      • In the “Display Name” field, type in your first and last names and click “Enter Meeting.”
      Teleconference
      • Dial (877) 793-5566 for public participants to access the audio platform.