Home Health & Hospice Week

The solution for quality and payment problems under PDGM may be something home health agencies don’t expect — more therapy services.

Of course, it’s not reasonable to expect there will be no utilization changes when the reimbursement system changes payment incentives, Goldsmith allows. After all, agencies “must survive” financially, he notes.

But HHAs must keep patient outcomes, including rehospitalizations, top of mind when making any moves toward efficiency, experts agree.

HHAs “need to move slowly and be able to prove why they changed,” advises attorney Robert Markette Jr. with Hall Render in Indianapolis.

“This is where I think COVID may be helpful,” Markette offers. “As we begin reopening and patients’ fear subsides, HHA utilization overall will begin to increase, from where it has declined to during the public health emergency.” That’s a great time for agencies to “consider how they are returning and changes they will make,” he believes.

For example: Take the increased use of telecommu­nications, Markette says. “Many agencies are going to be able to explain changes in utilization post-COVID in terms of reducing the number of visits to patients.” As COVID continues, “reducing patient contact will continue to be a goal. CMS has acknowledged the appropriateness of reducing in-person visits as a means to reduce the spread of COVID.”

Do this: “Agencies should consider what they have learned about reducing visits, utilizing telehealth, etc., and maintaining outcomes during the PHE,” Markette counsels. “Many agencies have learned that you can achieve a lot more with fewer visits than they ever would have imagined pre-COVID.”

Ultimately, “COVID will provide, for many agencies, a legitimate explanation of changes to utilization, due to both what we learned during COVID and a desire to limit the spread,” Markette concludes.

Of course, those justifications won’t apply to drastic utilization swings from before the pandemic, Markette emphasizes.

HHAs will need to be able to show that they are maintaining or improving patients’ outcomes during any changes. “As the home care industry continues to gain further stability in managing the pandemic, we may see utilization patterns begin to return to pre-pandemic levels,” Chimenti says. “As the MLN article suggests, the level of therapy service should be determined by the individual needs of the patient. The proper delivery of therapy service is integral to the optimi­zation of quality outcomes and the associated star ratings.”

Be prepared: “Agencies must remember, CMS is suspicious of changes in utilization patterns and agencies will need to be able to defend changes,” even when they are due to telehealth, infection control, and other legitimate factors, Markette urges.

Staying off reviewers’ radar for therapy utilization changes altogether may prove trickier than you’d think. “There is no magic number,” Goldsmith says of utilization norms — particularly since CMS hasn’t yet released PDGM data.