As part of an ongoing effort to provide input to the Centers for Medicare & Medicaid Services (CMS) and its contractors and help shape value-based care, Dr. Marc Rothman, MD, Kindred's Chief Medical Officer recently commented on efforts to develop potentially preventable readmission measures for all post-acute providers. As a provider of health care services and supports across the entire post-acute continuum, Kindred has a unique perspective about the value of each setting, actual success in reducing re-hospitalizations across all post-acute settings, and certain pitfalls to avoid in quality measure creation.

Within its comments, Kindred pointed out that it supports the development of measures to promote the delivery of high quality care to patients, and appreciates the opportunity to comment on measures that are a proxy for quality in health care delivery.  This is consistent with Kindred's endorsement of the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014 , which set the foundation for the establishment of cross-setting quality measures and served as an important foundation to pursuing step-wise reforms necessary for value-based post-acute care reforms.

Some of the specific recommendations offered by Kindred include:

  • Concerns with CMS' List of Potentially Preventable Conditions .  Kindred pointed out that the list is not specifically targeted at conditions for which readmissions from post-acute care should be preventable. Likewise, the most widely validated research on preventing hospital admissions among nursing home residents is targeted at long-stay custodial residents, not the short-stay post-discharge population who frequently move between multiple post-acute care settings. Therefore, Kindred recommended closer analysis of the evidence base for this measure and make modifications accordingly.
  • Insufficient Risk Adjustment . The current risk adjustment does not include the patient's functional status, one of the strongest predictors of hospitalization. Additionally, patients that require care in more than one post-acute care setting undergo multiple transitions and likely have more complex medical needs, increasing their risk of re-hospitalization. Thus, Kindred recommended adding both functional status and post-acute care utilization in the risk adjustment for the measure.
  • Too Many Duplicative Readmissions Measures . In its comments, Kindred pointed out that there are currently duplicative readmission measures for post-acute providers - noting that this would be the third such measure for home health.  Kindred recommended that CMS provide context for how it anticipates using or applying each measure to provide greater clarity to providers.

As CMS and its contract partners continue to seek stakeholder comment on other cross-setting measures applicable to all post-acute settings as set forth in the IMPACT Act, Kindred looks forward to providing comment and insight.