Ohio Health Quality Improvement Plan

Ohio Health Quality Improvement Plan Ohio Health Quality Improvement Plan

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Appendix IV — Co m m e n t s f r o mStatewide Or g a n iz a t io n sOhio Council for Home CareOhio Council is a statewide non-profit association thatrepresents 416 home health care and hospice providers. Wehave been advocating for clients, agencies and employeessince 1965.My responses to the strategies and tactics are in order of thedraft’s organization.Patient-Centered Medical HomesTask Force Tactics• Education – We can assist with all tactics listed undereducation as they include elements of the home caredelivery system.• Communication and Coordination – Home careplans to be involved since named as non-primary careprovider. We would also assist in the development ofchronic disease management programs.A tactic that appears to be missing is the utilization of“assessment” in care coordination. This is a function thathome health care has adopted as part of care management.The Leadership Council of Aging Organization (LCAO)developed principles one of which is the “AssessmentDriven Principle.” Care coordination must be based onan assessment, including, as appropriate, the individual’sphysical, mental, psychosocial, and cognitive functioning,spirituality, medication use, use of adaptive equipment, andfamily caregiver capacity to provide care.• Facilitation – The one action item that is a priorityfor home care is focusing on reducing hospitalreadmissions. Research studies conclude that utilizingcertain tactics by home care can effectively reducereadmissions within the first 30 days of discharge.In addition there are opportunities to also reduceunplanned emergency department visits when homecare is involved.• Evaluation – Home care currently uses clinical metricsin their delivery of care in addition home care isrequired to utilize the outcomes assessment informationset (OASIS) on patients. These strengths would benefitthe structure of the evaluation tactic.• PCMH Payment Models – A tactic that appears tobe missing is utilizing risk-adjustment which allowsfor the consideration of the complexity of individualconditions and the care coordination services. Therealso needs to be recognition for the amount of timenecessary to communicate with the individual andfamily or decision maker.• PCMH Decision Points – Question 4. Is a resoundingYES from us as we believe that the greatest impact andtransformation is with not just improving outcomesfor those with multiple chronic conditions, butmanagement of their conditions.Payment Reform• Tactic 1: please include recognition of tradeassociation so that we may be included.• Tactic 4: home cares knowledge of “avoidable adverseevents” comes as a result of OASIS data and outcomebased quality improvement (OBQI). Home care canassist with all tactics under Tactic 4.Informed and Activated Patients and Individuals• Health Care Treatment Decisions – the first set ofaction steps related to support health care treatmentdecision-making is a requirement of home care undertheir conditions of participation required by Centers forMedicare and Medicaid (CMS).• End-of-Life Decisions – Since this is what hospiceprovides, we can assist with all tactics listed.Side Note: The US Senate just introduced theComprehensive End-of-Life Care Legislation by Sen.Rockefeller, S. 1150. The four sponsors are all Democraticmembers of the Senate Finance.Missing from this section is the consumer protections piece.Either in this section or under care coordination thereshould be legal safeguards such as appeal rights, expeditedappeal, quality review and informed consent. I was unableto find anything regarding consumer protection under anysection of the draft plan.Ohio Education AssociationThank you for the opportunity to provide feedback relativeto the OHQI Plan. I would like to answer the first 3 of yourquestions directly, then add several recommendations to theproposed Plan.38

Appendix IV — Co m m e n t s f r o mStatewide Or g a n iz a t io n si.ii.I work with a number of organizations that could assistin the implementation of the plan; those include thepublic schools directly, and the School EmployeesHealth Care Board, School Employees RetirementSystem of Ohio (SERS), the State Teachers RetirementSystem (STRS) and the State Employment RelationsBoard (SERB) indirectly.The organization that I work for, the Ohio EducationAssociation, has been working for over a decadeto develop operational standards for health planadministration and evaluation to make up for the lackof such regulation in the school market. Our challengeis getting health plans and school organizations(schools and their health plan purchasing consortia) todevelop employee health risk management plans thatcan support healthy lifestyle choices and provide stressreduction opportunities.iii. The top priority should be to develop supply- anddemand-oriented solution sets in order to counterthe existing health system incentives that providepatients and providers with confusing and sometimesinappropriate behavioral signals for medical serviceoveruse, underuse and misuse.Having worked on the planning committee in preventionfor the HQII effort, I was gratified to find the importancethat ‘informed and activated patients and individuals’ hasfound in the proposed Plan. I would like to offer severalobservations and recommendations to improve that sectionof the Plan; I did not feel qualified to answer your questions(iv) and (v), nor to comment on the other sections in thePlan.The Gruman paper that is referenced on page 18 of the Planlays out the issues involved in patient engagement quitewell. However, the Plan re-names the concept ‘activation’,and does not take advantage of the comprehensive‘Engagement Behavior Framework’ as a potential metric.I would urge you to revert to the original wording in orderto facilitate clarity among researchers and practitioners,and would recommend that you expand your metrics tocreate engagement behavior baselines in a number ofpilot populations. Once completed, the results from thesesmaller populations could be folded into the ‘businesscase’ communications to drive the point home. In a similarmanner, other researchers are using small-scale studies toidentify the benefits of behavioral interventions on healthplan prices and individual health; see, for example, DeeEdington’s latest publication available from the Universityof Michigan Health Management Research Center (HMRC)(http://www.hmrc.umich.edu/).Again, thank you for the opportunity to provide feedback. Iremain more than willing to assist in the effort.Ohio Hospital AssociationOhio Hospital Association (OHA) appreciates theopportunity to be part of the Implementation Team of theState Quality Improvement Initiative, and supports thevision and principles articulated in the Ohio Health QualityImprovement Plan. OHA represents 178 hospitals andhealth systems throughout Ohio. Governed by a 21-memberBoard of Trustees, the association helps its members meetthe health care needs of their communities.The collaborative transformational strategies that comprisethe core of the Ohio Health Quality Improvement Planintersect with OHA’s sphere of interest at varying levels.In general, we support each strategy, within the context ofthe association’s own goals and principles for health carereform. In addition to supporting the objectives of thestate implementation plan, OHA also has several qualityinitiatives:• The Ohio Patient Safety Institute (OPSI), anorganization founded by OHA, the Ohio State MedicalAssociation and the Ohio Osteopathic Associationin 2000 to improve patient safety in Ohio. OPSIfocuses on strengthening and promoting policiesand principles to improve patient safety, identifyingstrategies to enhance patient safety in Ohio health-careorganizations, identifying barriers to implementationof strategies for improving patient safety anddeveloping strategies that overcome these barriers,promoting identification and dissemination of reliablepatient safety information to the public and providercommunities, and improving patient safety for allOhioans.• The OHA Quality Institute, created in 2008, withthe goal of driving transformational change in areas ofquality and safety in Ohio hospitals and to affiliatedproviders. The Institute includes OHA qualityimprovement collaboratives in Dayton (established in1999), Cincinnati (‘05), Columbus (‘08), as well as a39

Appendix IV — Co m m e n t s f r o mStatewide Or g a n iz a t io n s<strong>Ohio</strong> Council for Home Care<strong>Ohio</strong> Council is a statewide non-profit association thatrepresents 416 home health care and hospice providers. Wehave been advocating for clients, agencies and employeessince 1965.My responses to the strategies and tactics are in order of thedraft’s organization.Patient-Centered Medical HomesTask Force Tactics• Education – We can assist with all tactics listed undereducation as they include elements of the home caredelivery system.• Communication and Coordination – Home careplans to be involved since named as non-primary careprovider. We would also assist in the development ofchronic disease management programs.A tactic that appears to be missing is the utilization of“assessment” in care coordination. This is a function thathome health care has adopted as part of care management.The Leadership Council of Aging Organization (LCAO)developed principles one of which is the “AssessmentDriven Principle.” Care coordination must be based onan assessment, including, as appropriate, the individual’sphysical, mental, psychosocial, and cognitive functioning,spirituality, medication use, use of adaptive equipment, andfamily caregiver capacity to provide care.• Facilitation – The one action item that is a priorityfor home care is focusing on reducing hospitalreadmissions. Research studies conclude that utilizingcertain tactics by home care can effectively reducereadmissions within the first 30 days of discharge.In addition there are opportunities to also reduceunplanned emergency department visits when homecare is involved.• Evaluation – Home care currently uses clinical metricsin their delivery of care in addition home care isrequired to utilize the outcomes assessment informationset (OASIS) on patients. These strengths would benefitthe structure of the evaluation tactic.• PCMH Payment Models – A tactic that appears tobe missing is utilizing risk-adjustment which allowsfor the consideration of the complexity of individualconditions and the care coordination services. Therealso needs to be recognition for the amount of timenecessary to communicate with the individual andfamily or decision maker.• PCMH Decision Points – Question 4. Is a resoundingYES from us as we believe that the greatest impact andtransformation is with not just improving outcomesfor those with multiple chronic conditions, butmanagement of their conditions.Payment Reform• Tactic 1: please include recognition of tradeassociation so that we may be included.• Tactic 4: home cares knowledge of “avoidable adverseevents” comes as a result of OASIS data and outcomebased quality improvement (OBQI). Home care canassist with all tactics under Tactic 4.Informed and Activated Patients and Individuals• <strong>Health</strong> Care Treatment Decisions – the first set ofaction steps related to support health care treatmentdecision-making is a requirement of home care undertheir conditions of participation required by Centers forMedicare and Medicaid (CMS).• End-of-Life Decisions – Since this is what hospiceprovides, we can assist with all tactics listed.Side Note: The US Senate just introduced theComprehensive End-of-Life Care Legislation by Sen.Rockefeller, S. 1150. The four sponsors are all Democraticmembers of the Senate Finance.Missing from this section is the consumer protections piece.Either in this section or under care coordination thereshould be legal safeguards such as appeal rights, expeditedappeal, quality review and informed consent. I was unableto find anything regarding consumer protection under anysection of the draft plan.<strong>Ohio</strong> Education AssociationThank you for the opportunity to provide feedback relativeto the OHQI <strong>Plan</strong>. I would like to answer the first 3 of yourquestions directly, then add several recommendations to theproposed <strong>Plan</strong>.38

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