OIG Believes Unreported Falls Show ‘Poor Compliance,’ But Home Health Advocates Disagree

Home health agencies aren’t reporting more than half of falls involving major injury or hospitalization on patient assessments for Medicare beneficiaries, a recent report from the Office of Inspector General (OIG) found.

In order to compile this report, OIG looked for falls with major injury in Medicare hospital claims for home health patients, and then checked if these falls were reported in an OASIS assessment. OIG looked at assessments completed between July 1, 2020, and June 30, 2021.

The OIG study did not analyze why agencies did not report these falls.

“Reporting is a mechanism to monitor care – we want to be sure that we are improving not just the measure, but the care itself,” Katy Barnett, director of home care and hospice operations and policy at LeadingAge, told Home Health Care News in an email. “An investigation into the why of the non-reporting is critical to understand how to improve the measure for public use and to also improve the care of older adults, whether through enhanced communication between providers or other means.”

As a requirement, agencies are supposed to report when their patient’s experience falls with a major injury in patient OASIS assessments. The information that agencies self-report are used to calculate major injury fall rates by the Centers for Medicare & Medicaid Services (CMS).

Data compiled from OASIS assessments are also used to dictate Medicare home health payment amounts.

Additionally, CMS began using these fall rates as one of the quality measures on the Care Compare website — a resource for consumers — last year.

Broadly, falls are a major risk factor for seniors, and are costly. Among seniors, falls resulted in 920,000 hospitalizations and $70 billion in medical costs in 2020, according to CDC data.

OIG found that there 39,900 falls with major injury and hospitalization among Medicare home health patients between July 1, 2020, and June 30, 2021. Of the 39,900 falls, 55% went unreported by agencies on OASIS assessments.

“Given that CMS requires HHAs to report the number and severity of falls in OASIS assessments, the high rate of non-reporting indicates poor overall compliance among [home health agencies],” OIG wrote in its report.

Falls went unreported more often at for-profit agencies compared to any other type of agency, according to OIG’s findings.

Plus, a larger percentage of falls with major injury went unreported for Black, Asian and Hispanic patients, compared to White patients. Specifically, 66% of falls among Asian patients went unreported, 65% for Black patients and 64% for Hispanic patients, compared to 54% of White patients.

The study also found that when looking at age demographics, seniors who are 85 years and older had the lowest percentage of falls not reported at 52%. Meanwhile, seniors who are less than 65 years of age were the highest at 64%.

Patients who qualified for Medicare because of a disability were less likely to have their falls reported than those who qualified because of their age.

Home health stakeholders have pointed out that these findings don’t paint a complete picture of what agencies are experiencing on their end.

“A major issue in utilizing the inclusion of falls with major injury in the OASIS assessment is the availability of accurate and timely information of the event occurring,” Andrea Devoti, executive vice president at the National Association for Home Care & Hospice, told HHCN. “When a patient or their caregiver(s) decide the patient should be taken to the hospital during an episode of care, there is no mandate that initiates automatic notification of the entity providing care in the home. Most of these decisions are made when there is not [home health agency] personnel there. Despite there being written information available on how to notify the [agency] in case of emergency — that is the last thing that a family member thinks of during the crisis.”

Devoti also pointed out that ambulance companies and hospitals aren’t required to notify previous entities involved in the care.

“Finding out the patient went to the hospital occurs when the HHA reaches out to confirm an upcoming visit,” she said. “They are told the patient went to the hospital, not why, or if they were admitted or are in observation status, or any further details even with careful questioning. So, the discharge to hospital OASIS is submitted without the fall with major injury being noted. The readmission or admission OASIS only indicates the reason for the admission, or readmission to the [agency]. The admitting clinician does not, in most cases, have the entire chart to rectify, hence the report never gets filed with the fall information on it.”