Purpose:
The purpose of this Request for Information (RFI) is to determine the implications of eliminating the use of the Hospital and Community (H/C) Patient Review Instrument (PRI) DOH-694. The RFI seeks recommendations for a replacement assessment tool, if necessary. New York State hospitals, nursing homes, home care providers, and assisted living providers are encouraged to submit responses. We also encourage the public and organizations representing consumers to reply. Responses submitted through this RFI will inform the Department's decision whether to eliminate the use of the H/C PRI.
Background:
In 2017, under the direction of Governor Cuomo, the New York State Department of Health (the Department) led the Regulatory Modernization Initiative with the goal of streamlining and updating existing policies and regulations across a range of areas to best meet the needs of patients, providers, and payers. As part of this initiative, the Post-Acute Care Management Models workgroup focused on improvements that would put patients at the center of a coordinated, cohesive health care system with smooth care transitions. The workgroup included members from home care, hospitals, assisted living, primary care, health plans, and various other stakeholder groups from across the state. The workgroup's recommendations included eliminating the use of the H/C PRI.
The Department regulations have numerous references to the PRI. It is important to note that there are two forms that are commonly referenced as the PRI. One is the H/C PRI (DOH-694), the subject of this RFI. The other is the nursing home reimbursement PRI (DOH-3), which is no longer in use.
The nursing home reimbursement PRI (DOH-3) was used for nursing home reimbursement purposes from 1986 through March 2009. Statutory provisions contained in Chapter 109 of the Laws of 2006 repealed the requirement that nursing homes submit DOH-3 PRIs in 2007 and 2008, giving facilities the option to file the DOH-3 PRI in those years. Effective April 1, 2009, the Department transitioned to the Minimum Data Set (MDS) (NYCRR 86-2.40) as the measure of nursing home patient acuity. No new DOH-3 PRI submissions were permitted after 2008 since the State transitioned to a new reimbursement classification system using the MDS.
The H/C PRI (DOH-694) is used as an admission tool along with the SCREEN (DOH-695). In New York State, individuals who require placement or continued stay in Residential Health Care Facilities (RHCF) must be assessed to determine the appropriateness of placement and level of care required. These assessments are conducted by Registered Nurses who have been trained and certified in use of the Department's H/C PRI and SCREEN forms.
Preliminary feedback gathered through the RMI process suggests that the value of the PRI may be limited. It is alleged that the H/C PRI assessment does not help hospital and nursing home staff or improve care provided to the patient. Hospital staff only conduct H/C PRI assessments upon a patient's discharge to a nursing home. Discharge staff are often unfamiliar with the patient upon completing the assessment, and there is no hospital purpose for the H/C PRI beyond the discharge requirement. Within a reasonable period of time after admission to the nursing home, a complete assessment is conducted by the nursing home using the Resident Assessment Instrument and the federally required MDS tool, not the H/C PRI. Additionally, the H/C PRI is no longer needed as a tool to prevent inappropriate nursing home utilization. Under managed care and emerging value-based payment arrangements, there is significant interest in reducing preventable nursing home utilization by providing care to people in their homes or other community-based settings.
Information Request:
The Department is seeking information from all providers, but is especially interested in responses from New York State hospitals, nursing homes, home care providers, and assisted living providers. We also encourage the public and organizations representing consumers to reply. Responses should include information on the current use of the H/C PRI in the provider's setting, the implications for eliminating the use of the H/C PRI, and recommendations for a process or tool to replace the functions of the H/C PRI, if necessary.
Please review the questionnaire and include your responses and recommendations. Respondents are asked to use the template provided and to submit their response in Microsoft Word.
Please send responses and recommendations to ALTCteam@health.ny.gov with the subject line "PRI RFI". Responses should be sent no later than 5 p.m., April 30, 2018. Information in addition to the prescribed questions is welcome. Your time and input are greatly appreciated.
This RFI is for planning purposes only and should not be interpreted as a solicitation for applications or obligations on the part of the Department. The Department will not pay for the preparation of any information submitted or for the use of that information.
The Department will use the information submitted in response to this RFI at its discretion and will not provide comments to any responder's submission. However, responses to the RFI may be reflected in future funding opportunity announcements. The information provided will be analyzed and may appear in reports. Respondents are advised that the Department is under no obligation to acknowledge receipt of the information or provide feedback to respondents with respect to any information submitted. No proprietary, classified, confidential, or sensitive information should be included in your response. The Department reserves the right to use any non-proprietary technical information in any resultant solicitation(s).
