Home Health Quality Assurance: 2018 COP Requirements

The new COPs require a heavy data driven QAPI program that agencies can utilize as justification of care and the defense of having a home health license to operate. However, at the same time, agencies are having a difficult time determining what type of program to develop and how to start such a program.

First, agencies must get the whole agency involved. This doesn’t just mean the nurses who do the OASIS – it means everyone – nurses, therapists, all clinical, contract, and office staff. Quality goes beyond the manipulation of OASIS data to make an agency’s star ratings go up or down. Understanding which measures contribute to your star ratings is a good place to start, but we must go beyond this, much further beyond this focus.

Second, agencies need to have a good understanding of data that is available to them. Agencies that are still on paper will have the most difficulty with this task. Agencies that have electronic software platforms should be able to run reports and import the information into Excel to create spreadsheets and Pivot Tables.

With this data, agencies can summarize the information and analyze what is happening. But to get here, agencies must first select the data they wish to measure. Don’t go overboard in the beginning – take it slow. Understand your agency’s personnel and software limitations. Identify what you want, what you can get, and what you want but can’t get from your information.

For instance, many web-based software platforms have limited data available through interactive reports. Most platforms in use, whether they reside in your office or online, allow reports to be imported to Excel. From Excel, you can manipulate the data. However, you have to know how to use Excel. If staff aren’t able to use Excel – this is going to be the first step in your QAPI plan. Once you can manipulate data easily, tracking your measures and creating summarized reports for analysis is going to be very easy.

While gathering data seems like an arduous process or potential waste of time, it isn’t. Doing so actually helps your agency stay in compliance with the COPs. Just pulling the information together in a spreadsheet and reviewing it, you are crossing the safety line of having a QAPI program in place.

Let’s take a couple basic measures that are familiar to staff and agencies: hospital admissions and re-admissions. Log into your software and run a discharge report for the 4 quarters of 2017. If the information isn’t summarized by discharge reason, you will need to put the report into Excel and sort and filter. For the adventurous Excel users, a Pivot Table can provide a summary of discharges by reason in seconds. Depending on how your software and agencies track information, you could have several discharge types listed for hospitalizations.

Open a new spreadsheet and begin to input the information on the reports in rows (discharge/hospital admission reason) and columns (quarters). Then enter the amount of each discharge reason in the rows under the quarter in which the hospital admissions occurred. Now we have a tracking tool to begin to analyze what is going on. Did your agency have many hospital readmissions or did it have a few? Either way – why?

You need to dig into this data and find out what is going on – what are the reasons behind these numbers. Once you have the reasons why, you can begin to formulate a plan as to how to prevent them. We’ve all been talking about hospital re-admissions for years but now you just can’t ignore them anymore, hoping your other star ratings will help offset them to get to a 3+ star rating.

The COPs require you to do something about them and CMS wants to see the data, proof, and plan in writing. Surveyors are going to be instructed to look at this information and if you don’t have it – you will be cited and forced to scramble to get the information as part of your plan of correction.

After you have one measure down – it’s time to begin to track other measures and outcomes. But you have to make sure your agency is acting on the data it has in front of staff in meetings. Does the data get analyzed or is it just shoved into a folder or a binder waiting for the next survey? Or are you going to actually make an effort to truly focus on a QAPI program?

This isn’t going to be cheap – there is nothing in the regulations that say a QAPI fairy is going to sprinkle magic dust over your agency, giving you what you need with the snap of your fingers. In fact, you could talk to 10 different agencies and each one is going to tell you something different as to what they would like to measure, how they measure the data, and what the standard will be while staying within a defined agency-acceptable deviation.

Your agency isn’t only going to need to focus on clinical measures and outcomes. The agency must also focus on operational data, patient safety measures, and quality of care. Larger agencies have been doing this all along. Smaller agencies do this ad-hoc and usually anecdotally because of the smaller volume of patients and closeness between agency and patient. You need the data.

Just because one of your nurses knows the intimate details of Mr. Jones’ vitals, his entire medical history, and how to take care of him – this isn’t going to matter unless you’re making a marketing video for Facebook and YouTube. (If you do have a nurse and patient like Mr. Jones – this could be a good opportunity to tie in quality of care and statistics you accumulate to promote your agency.)

Have you identified areas where your agency can improve? Have you defined how you will make those improvements? Who’s responsible for making sure these improvements are implemented and tracked? Will you have interim reporting to make sure you are on track or will you wait for the quarterly meeting?

Your QAPI program will need to focus on risk management and education. How will you identify patients who are at high risk for readmissions, falls, and potential abuse in the home? This must be done at admission and the patients must be tagged to track these and other risk factors. Does your area have a higher population of need in one type of care over others? For instance, if your agency is in a city versus in a suburban or rural area, the population needs will be different. This will require a different set of risk assessments. Patient service areas will need to be grouped together for this purpose to really promote a succinct QAPI program.

These projects where you develop the program are part of the standards of the new QAPI initiative. Documentation of the purpose and reason is necessary along with the final outcome of what is going to happen with the information when complete. Did you implement the finding recommendations or determine that the study was useless? Either way, you must document the reasons.

The governing body will be responsible for making sure the QAPI program is in effect and being run in accordance with the COPs. The governing body for most agencies is the owner and sometimes a few key employees and trusted advisors. Now that the typically expensive and useless Professional Advisory Committee was removed from the COPs, the governing body will be responsible, on paper, to ensure the agency is meeting the QAPI standards.

To further complicate the QAPI program, agencies must also include and implement a method of detecting fraud and abuse. Once detected, agencies must have a process in place to quickly stamp out the fraud or abuse and waste by reporting it to the proper authority.

The new QAPI COPs are daunting but they don’t have to be. You can start small and work your way up. Agencies should be doing some of these QAPI tasks already and depending on your software, some of this data collection may already be happening. If not, you do have a project ahead of you, but breaking it up and assigning staff to help will make the program run more effectively than trying to be a COP martyr doing it all by yourself.

We will be continuing to provide guidance on developing a QAPI program along with other important new COP implementations that agencies must undertake. We’d also value your input and opinion on what is affecting your agency, what you are having trouble with, and what areas you’d like more information on.

While the COPs are heavy on data and analytics, common sense is still an important part of running your agency. Don’t lose control or focus on growth, overhead, and watching industry wide performance indicators. If you aren’t tracking these, 2018 is going to be the year to start. Our performance dashboard provides you with the indicators you need to focus on and can be incorporated with your QAPI program. When you email us your thoughts, mention the dashboard and we can help get you going!

Hint: Checkout YouTube for Excel training for your staff. There are many excellent tutorials that will guide you step by step to manipulate data and create tracking tools.

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