When medical instructor Carol Siebert, MS, OTD, isn’t teaching OTD students or serving patients through her private practice, she’s immersed in her work on two federal rulemaking committees for the Centers for Medicare and Medicaid Services (CMS).
CMS uses a consensus-based process that works in partnership with the healthcare community to improve quality, equity, and outcomes in the healthcare system. For over two decades, that process was administered by the National Quality Forum under contract with CMS. This year, the contract was awarded to Batelle/Partnerships for Quality Measures (PQM).
Dr. Siebert brings her expertise as an occupational therapist in home-based care and rural health settings to the process that endorses qualified measures that are used to determine a range of rules and standards across our nation’s health care systems. Measures can be used to determine payments, help to make clinical care decisions, and prioritize improvements.
For more than three decades, Congress has mandated healthcare quality metrics in legislation. The Biden Administration is focused on utilizing these measures to advance priorities that include addressing healthcare disparities, reducing the per-capita cost of healthcare, improving the experience of care, and improving overall health.
But where do the measures come from? And how are they determined?
The answer to both questions is at the heart of Dr. Siebert’s committee work. This fall, she was appointed to two PQM committees:
- Pre-Rulemaking Measure Review (PRMR) for Post-Acute and Long-Term Care
- Endorsement and Maintenance Committee for Advanced Illness and Post-Acute Care.
Having served on similar rulemaking committees since 2011, she has been following PQM's efforts to simplify the complicated, bureaucratic consensus-based process which has resulted in a new structure and fewer committees. She decided to throw her hat in the ring to serve in some capacity.
“I put in my nomination. I have spent my entire career – which will be 35 years this February – working mostly with older adults in their homes, so I know this from a grassroots level as well as understanding quality metrics because I am out there on the front lines caring for people whose lives and experiences in health care don’t necessarily look like the numbers,” she explained.
The government contracts with a vendor to serve as the Consensus-Based Entity (CBE) that administers the “transparent, consensus-based process that incorporates feedback from diverse groups of stakeholders to foster health care quality improvement.”
Quality measures have become a driving force in healthcare and these “quality metrics” play a role in performance (or practice) improvement, accountability, and payment, she explains. For instance, in the past two months, CMS has released final rules for all types of healthcare settings and providers which include measures for accountability and in many cases, payment that go into effect in 2024, Dr. Siebert explains.
“The point of a measure (of quality) is not just to measure but to improve the quality of care,” she said. “So, there is a lot of discussion about the burden of implementing a measure – vs. what the value in implementing a measure,” she said.
For more than 20 years, she has been part of a home-based primary care project that serves low-income residents, giving her an up-close view of healthcare disparities and system shortfalls.
Siebert’s experience benefits the students enrolled in OTD 602 - Occupation, Occupational Therapy, & Care Systems which covers service delivery models, policy, regulatory bodies, reimbursement systems, credentialing requirements, ethics, liability, and expectations for lifelong career development. The course places an emphasis on how OTs can influence systems to create contexts where their distinct contributions can directly improve patients’ lives.
She has seen many positive developments in the profession and she’s passionate about OT’s role in advocacy.
“Teaching this content and being involved in committees has opened my eyes to a lot of things like how we communicate what we do and how we relate it to the rest of the health system,” she said.
For example, medical doctors hear the word rehabilitation/rehab and think of it as a population or facility associated with specific post-acute conditions. But the reality is – she explains – that 1 in every two Americans is managing a chronic, potentially debilitating condition.
“We have to continue to place OTs at the center of helping these people manage these chronic conditions so they can manage the activities of daily life,” she said.
OTs have exciting and distinct opportunities to play a critical role.
“I don’t expect people to be policy geeks but there is a way to blame the payment system or the policy system and feel like you are sitting in this very narrow (OT) box,” she said. “The opportunities out there for OTs are endless but part of it is being able to communicate our perspective and to keep up with our understanding of how the system works.”
She stresses the need for students and all OTs to stay informed and engaged.
“Advocacy isn’t just about going to Raleigh or going to DC or writing a letter to your Congressional representative, it’s understanding how the system works, and how what you do fits into the system and where that ultimately contributes to delivering quality care,” she said.
Dr. Siebert’s roots in this vital work span two decades. Representing the American Occupational Therapy Association (AOTA), she participated in one of the Centers for Medicare & Medicaid Service's first rollout of performance improvement measures in healthcare.
She has served several committees focused on home health improvements, along with the Joint Commission Standard’s Survey Procedures Committee and the Physician Consortium for Performance Improvement’s Measures Advisory Committee. Until recently, she represented AOTA as a member of the NQF Prevention and Population Health Standing Committee
“I’m a policy geek. I know most people are not. But I’ve seen how quality measures have had a marked impact on healthcare in the past 20 years. Preventing rehospitalizations was not really on anyone’s radar 20 years ago. Now it’s everyone’s priority—in part because it figures into the payment algorithm for hospitals and several other practice settings,” she said.
She encourages everyone to visit Medicare Care Compare to review and compare quality ratings on Medicare-certified facilities and any Medicare-enrolled providers.
“Quality measures matter, and not just to policy geeks. As a practitioner and as an instructor, I think it’s important for clinicians to understand the relationship between policy and practice, and to connect what they do daily to the big picture of health and healthcare in this country. Being on these committees means I have a voice in the measures that are driving the system,” Dr. Siebert said.