CMS Leaning Into GG Functional Scores
CMS has proposed to move to the GG items (GG0130 and GG0170) to create the functional measure scores used in the future for both Home Health Value Based Purchasing (HHVBP) and for consumer reports on Care Compare.
FAQ:
When will the GG items be used for payment or quality outcomes, such as HHVBP or five-star?
It was proposed in the 2024 proposed rule by CMS that the GG items would be used in 2025 for a Discharge Function measure to be reported on Care Compare, and for HHVBP. There has not been any announcement of when the GG items would be used instead of the M1800s for PDGM.
The Least You Need to Know:
In the 2024 proposed rule, CMS aims to start using the GG items (GG0130 and GG0170) to create the functional measure scores used in the future for both Home Health Value Based Purchasing (HHVBP) and for consumer reports on Care Compare.
The IMPACT Act (Improving Medicare Post-Acute Transformation of 2014) mandated that CMS begin aligning “like measures” across the post-acute continuum. Using the GG items from the OASIS would allow multiple PAC sites to use the same measures. The GGs have slowing been migrating into the OASIS, but unfortunately, agencies have had to do double duty and complete the legacy M items that were “similar” to the GGs- but not similar enough to create a crosswalk for payment or quality. This is the first time CMS has proposed to use the GG’s for quality or HHVBP.
Details:
The Discharge Function Score is a measure that is VERY different than our current functional scoring system. Currently, in the M1800s, we are looking to see if there has been improvement (and in the TNC, how MUCH improvement or change) has occurred between the SOC/ROC item and it’s corresponding item at DC. In the new Discharge Function Score, CMS will view the total score of specific GG0130 and GG0170 items, and compare that score sum to what would be “anticipated” for a similar patient. Below is a table of those specific items impacting the score:
The data providing the “norm” of this similar patient includes the following “risk adjustors”:
Age at time of SOC/ROC
Admission functional score (GGs added up- give score 10-60)
If NA- CMS will impute here too
Prior surgery
Prior functional level/device use
Pressure ulcers
Cognitive functioning
Incontinence
Availability of Assistance and Living Arrangements
Admission source
Body Mass Index These covariates indicate whether the patient has a low BMI (12 ≤ BMI ≤ 19) or high BMI (>50).
Risk for hospitalization These covariates indicate a history of falls, multiple hospitalizations, multiple ER visits, decline in status, non-compliance, or polypharmacy prior to SOC/ROC.
Confusion These covariates indicate whether the patient has moderately frequent or severely frequent confusion in the 14 days prior to SOC/ROC.
Vision These covariates indicate whether the patient has partial or severely impaired vision. • Medication Management Needs These covariates indicate whether the patient needs medication management assistance for oral or injectable medication.
Supervision and Safety Sources of Assistance These covariates indicate whether the patient needs and has non-agency caregivers with proper training
And, specific ICD-10 co-morbidities…
Perhaps, the most concerning part of this new measure is when the clinician answers an “NA” response, including 88, 09, 10 and 07. In these circumstances, CMS will “impute”- or in other words, provide an educated guess based on data, what that true performance should be.
All of this news certainly causes some concern and really a great catalyst to start our engines on proper GG training! 2023 is the “baseline year”- so before next year, be sure all clinicians performing or providing audits on OASIS are experts in this area! We will be providing more tools and education in the future on this very topic!
Your Actions to Take:
ONE Assess your agency’s current use of the “NA” scores in the GG0130 and GG0170 items
TWO Create and provide trainings on the GG items for all staff involved with OASIS. Remember Home Health Fundamentals Flashcards from 2022 on the GG items!
THREE Ensure your QA has incorporated the GG items in their oversight