2022.01.26 EQRS Program Working Group Meeting

Status on questions and suggestions captured at the 11/30 PI16 System Demo

Please review for all questions: Nov 30 2021 EQRS System Demo Questions_Suggestions_01262022.docx

Recording for this discussion: 8:37 - 35:11

• Todd Johnson oversees the ESRD network program; working with the SMEs for transplant and depression areas
• Disclaimer: there are some portions for transplant the SME has not seen the actual module so we will have to revisit any related questions until the SME has a chance to perform a deep dive.  Also items highlight in orange are procurement sensitive information on those will be provided at a later date
• CMS' comments can be found in the "CMS Comments" column of the table

Question #1: If the patient is screened for cognitive decline, there is a place to enter a score. No score is required for depression screening. 

• Do we know the if the intent of the score is for cognitive decline or if it is for depression screening?
  • Per Todd, no we do not know that; will need clarification
  • Per Nathan, there was one of the fields that said to provide the score; its not clear on what the score is for
  • Suggestion to clarify in the description of that field what is the score for the cognitive decline assessment or depression screening assessment so folks know what score they're being asked for
  • Per Scott and Yvette, the score that is mentioned is for cognitive decline
  • Question from Vlad - Do we need to report both scores for depression screening and cognitive decline?
    • Per Kathleen - she does not think so, only one needs to be reported
    • Per Vlad - if you report a score for cognitive decline and not for depression screenings, what is the point of doing screenings?
  • Per Nathan - another concern is that there is not no standard assessment for cognitive decline and so just collecting a random score from different provider will mean different things
  • If the expectation is then comparing those scores across patients, you really won't be able to do that; you won't know which assessment is being used and how the scores related to each other
  •  There is a concern that as indicated in the document presented under the CMS Comment field cognitive decline should also be screening for depression is shifting the whole expectations of depression screening an adding a new screening of cognitive decline
  • The EDIs concern with this whole new Identity depresses patients is that they have not been clearly told what the expectation is besides some statistical analysis that says dialysis patients should be more depressed but the depression assessments don't show that
  • The intent of the data has never been understood so the EDIs can actually get it to achieve what CMS wants to achieve
  • Additional concerns about the level of truth of some of the questions and the ability to share of that data
  • Per Shalon, we are trying to look at the whole patient and trying to address any issues they may have and trying more accurately to capture that and screen patients and get them treatment
  • Per Nathan, depression screen assessment is not a diagnosis of depression so somebody could do the assessment today, not show as depressed b/c it's only good for a two week period
  • In addition, patients who already have a diagnosis of depression are considered an exclusion population from the assessment itself b/c they've already been diagnosed
  • Concerned that CMS/Program is comparing apples and oranges without fully understanding the two different sets of data and how they can relate to each other
  • Per Howard, their board has been discussing this and concerned about whether the personnel and the dialysis clinics are truly licensed to render a depression diagnosis
  • Per Todd, his understanding was that the social workers in the dialysis clinics would not be actually diagnosing but just leaning towards a referral
  • Per Howard, they are administering a tool but then need some guidance from the program and CMS
  • Per Rachelle Caruthers, they are not simply being asked to refer, but being asked to increase the number of patients that actually attend; that maybe outside the scope/control of the social worker in a dialysis clinic
    • In the statement of work it specifically says to increase the percent of patients who have received treatment by a mental health professional, so the statement of work is going far beyond referrals
  • Per Howard there are a lot of questions that tie into this that need to be addressed/given attention
  • Todd - How to address the issue about the diagnosis
    • Clinics that have licensed clinical social workers; they would be able to screen and make referrals
    • Social workers that are even not clinical can screen and refer depending on license level
    • We are NOT asking them to diagnose, but asking them to identify any issues the patient may have based on the screening and overall assessment of the patient
    • Per Howard we should say if the patient was offered a referral for mental health services, given the screening or the patient assessment. Trying to put down a score will open up a can of worms.  Keep the question simple. "Was the patient offered a mental health referral?"
    • Nathan agreed to Howards suggestion
  • Todd will need to talk to the SMEs around this area just discussed (action item)
  • The other piece is to be able to confirm if the patient has sought treatment or is in treatment, etc
  • Per Howard this could get into the State Law issues; could be sensitive information
  • Still need clarity on the cognitive decline score issue
    • Concern is there isn't a set of standard rules that are utilized
    • Collecting data around that isn't comparative data b/c there isn't a single tool that's utilized by the industry
    • Todd will discuss this with the SMEs (action item)
• Question from Nathan
  • • Why are the questions in orange on the document are procurement sensitive?
      • Per Todd, we are in procurement at this time and cannot address those questions highlighted in orange
      • The Program will circle back with the group as soon as they can

Recording for this discussion: 35:19 - 38:42

Question #4 The question “Has the patient completed a depression screening this month?” conflicts with the quarterly reporting requirement.

Question #7 What is CMS’ expectation around screening patients for depression? Most screen annually. 

• • Right now the EDIs are expected to assess patients annually under the QIP measure
  • EDIs have never been able to get clarity on the expectations of this new data collection 
  • They have been told to report the data quarterly for patients that were assessed in that quarter
  • Other times they have been told to report monthly for patients that were assessed in that month
  • Also have been told screening every patient at least quarterly and reporting on all patients quarterly
  • Ideally the EDIs would continue to meet the QIP requirements and provide assessments annually
  • Then report this additional data on those patients that were screened
  • Another concern is the timing of the reporting of the additional data
    • For example, I get an assessment this week, my receiving of treatment for mental health may not happen for 3-4 months for a variety of reasons
    • How do we address the timing of reporting the follow up that's feasible for the assessment actually being done allowing intervention to take place? Initially the reporting was going to be done by the end of the month.  There is not time for action to take place

Admission in Support of Transplant

Recording for this discussion: 39:37 - 58:48

• Kathleen had a question about: "If admission reason is New to ESRD (because first episode is transplant), can the Admit Reason be Dialysis in Support of Transplant?"
  • Per Michael, if they have had a transplant and it is in America, then they're new to ESRD would be a transplant and then it should just be a dialysis in support of transplant as their second event
  • If they had a transplant somewhere else, and they were first coming into this country as a dialysis patient, it would just be new to ESRD dialysis
  • If Kathleen try's to send admission is the dialysis and support a transplant will she get and error that says "your admission reason can't be dialysis for support of transplant b/c previous admission is new ESRD?
  • Per Michael, need to confirm that if it's new to ESRD with a transplant modality
  • Per Yvette is it allowed and that can be the next admission; that's not new, it is how the system works today
• Per Nathan - there was discussion if a patient is receiving dialysis and support of transplant and the transplant was determined to have failed.  How does that get handled from the dialysis perspective? Do we keep the admission?  Change the type of admission? Do we need a new admission reason? Discharge reason?
  • Per Yvette, when they were initially capturing the requirements for this feature from Lisa, she did not give different or a new discharge reason for dialysis and support of transplant. 
  • Right now the reason would still be death; that's where the conversation came up about who's going to enter the death form
  • Suggestions from EDIs said CMS should enforce it where the transplant facility would be responsible for creating that 2746 and not the dialysis facility
  • Nathan said the discussion was not if the patient dies but what if the transplant was determined it had failed and the patent has to go back on dialysis
  • Per Yvette, the decision was that a new admission would be created for that dialysis facility and the admission reason would be "dialysis after transplant failed"
  • Per Kathleen she believes a decision was not made and needed more discussion
  • Historically, direction has been given that the admission date back dates to the first treatment
  • A discussion needs to be, is that still the case or should there be a new admission?
  • Is it just changing the admission reason to fail?
  • This will have to be a program decision
  • Per Michael, Lisa wanted a second admission for the reason that she wanted to be able to track dialysis and supportive transplants apart from failures.  He feels this can be tracked a couple ways and neither are incorrect so the Program needs to help in how to handle this
  • EDIs need to understand the business rules the program is expecting for this
  • Once a decision is made we need to fully understand the impact this new admission and new discharge are going to have on QIP and five star and attribution to the clinic
  • Howard expressed a concern about doing a temporary one off admission; it will be difficult to communicate to frontline staff; may cause a confusion impacting the data
  • Second concern is NRAA system may not be able to accommodate this secondary admission
  • Suggest for CMS to step back and simplify this rather than make it complex
  • What is done now when a person who got a transplant comes in and you're giving backup dialysis and then become permanent failures, what do your clinics do now?
    • Per Nathan, they do not report the backup to EQRS b/c it's considered transient; internal documentation/paperwork is done but reported to EQRS

Next meeting scheduled for 09 Feb 2022