Home Health & Hospice Week

Retroactive benchmarks curb quality improvement, critics say.

Home health agencies in the nine Value-Based Purchasing states feel like they may be working in the dark when they don’t have to.

Why? HHAs under VBP have gotten their initial performance reports, but they have no idea how they compare with their peers. That means they are already mostly done with the first reporting year for VBP and have little clue about whether they’ll receive a bonus or penalty in 2018 based on 2016 data.

The Medicare Payment Advisory Commission, for one, would like to see that change. “Setting benchmarks after the reporting period is problematic because agencies will not know in advance the level of performance or achievement that is necessary to avoid a penalty or earn a bonus,” MedPAC says in its comment letter on the 2017 HH PPS proposed rule. That will discourage HHAs from investing time and resources into quality improvement, the Commission predicts.

“Without knowing the benchmarks to be achieved in advance, we will be unable to clearly work toward avoiding a penalty or achieving a bonus,” agreed the California Association for Health Services at Home in its comment letter. “It is vital that any entity being evaluated know by what standard they will be evaluated in advance so that they may properly prepare.”

Instead: “CMS should establish the benchmarks for each quality measure based on historical performance,” urged the Virginia Association for Home Care and Hospice in its comment letter.

Stay tuned for CMS’s forthcoming 2017 final rule, expected within a few weeks, to see whether the agency heeds MedPAC’s and others’ advice.