Wednesday, September 14, 2016

AHCA/NCAL Submits Comments on Proposed Standardized PAC Patient Assessment Data Elements

Dan Ciolek

On September 2, AHCA/NCAL submitted a 33 page comments document to the Centers for Medicare and Medicaid Services (CMS) contractor, the RAND Corporation, in response to a request for comments pertaining to a Data Element Specifications for Public Comment document prepared under the CMS Development and Maintenance of Post-Acute Care Cross-Setting Standardized Assessment Data project.

The Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act of 2014) requires that the Secretary of the Department of Health and Human Services implement submission of standardized data from post-acute care (PAC) providers using the assessment instruments that CMS currently requires for use by home health agencies (HHAs), inpatient rehabilitation facilities (IRFs), long-term acute care hospitals (LTCH), and skilled nursing facilities (SNFs). It requires the submission of standardized data on specified assessment domains and specified quality measurement domains. It specifies that the “data be standardized and interoperable so as to allow for the exchange of such data among such post-acute care providers and other providers and the use by such providers of such data that has been exchanged, including by using common standards and definitions in order to provide access to longitudinal information for such providers to facilitate coordinated care and improved Medicare beneficiary outcomes….” In the SNF, the Minimum Data Set (MDS.3.0) is the patient assessment instrument where these cross-setting data elements would be located. It is to be determined whether these elements would replace, or be added-to the existing MDS 3.0 data elements.

In this comments document, stakeholders were asked to comment on 22 distinct proposed cross-setting data elements within the categories of:

1) Cognitive Function and Mental Status
2) Medical Conditions: Pain
3) Impairments of Hearing and Vision; and
4) an array of 12 specific Special Services, Treatments, and Interventions.

The AHCA/NCAL comments emphasized support for the objectives of the IMPACT Act, but that more work was needed on the development of the proposed standardized cross-setting data elements. Recommendations were offered to address general concerns that changes to existing MDS item definitions and/or reference lookback windows may 1) impact existing SNF Medicare and Medicaid case-mix payment models and quality measures, and 2) create significant additional SNF provider burden. The AHCA/NCAL comments related to the individual data elements were intended as stand-alone item-specific comments and were generally structured as follows: 1) summary of the proposed data element, 2) AHCA/NCAL’s position on the cross-setting importance of the data element domain, 2) components of the proposed data element that AHCA/NCAL supports, 3) AHCA/NCAL’s impression of the impact of the proposed data element on SNF MDS 3.0 reporting, 4) AHCA/NCAL’s recommendation for next steps for the proposed data element before we can support it, and 5) AHCA/NCAL’s rationale for the recommended next steps.

If you have questions regarding the AHCA/NCAL comments please contact Daniel E. Ciolek, Associate Vice President, Therapy Advocacy at

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