Home Health & Hospice Week

Innovation Center is changing course.

If you’re wondering whether Home Health Value-Based Purchasing will be postponed as many home health agencies have requested, a new white paper from the Centers for Medicare & Medicaid Services may give you a hint.

Reminder: In the 2022 home health proposed rule, CMS proposes that VBP be extended nationwide in January.

HH VBP is one of the only CMS Center for Medicare and Medicaid Innovation payment models to have generated savings for the program, CMS says in a 32-page white paper on the Center’s “strategy refresh.” (The other models that have shown “statistically significant savings” include the Maryland All-Payer Model (MDAPM]; Repetitive, Scheduled Non-Emergent Ambulance Transport [RSNAT] Prior Authorization Model; the ACO Investment Model [AIM]; the Pioneer ACO Model; and the Medicare Care Choices Model [MCCM].)

And under its new direction, CMS is emphasizing care at home. CMS wants to “design models that give providers … tools that enable the delivery of integrated, whole person care in the settings beneficiaries prefer, such as in the home and community,” CMS’ Purva Rawal said in an Oct. 20 webinar about the new strategy.

“Moving forward, payment and regulatory flexibilities for model participants will be examined that can support the provision of home or community-based care, especially in models that are moving towards or that encompass total cost of care,” CMS says in the white paper.

Those two priorities — cost savings and home-based care — indicate that CMS will be loath to put VBP on ice, observers suspect. However, a brief delay for practical reasons may still be possible, they concede.

The Innovation Center also plans to test fewer models, CMS officials said in the webinar. “We’ve learned that testing almost 50 models simultaneously, many in the same market, and with the same providers, without clear guidance on how savings can be shared, can lead to confusion and complexity,” admitted Innovation Center head Liz Fowler in the session. “This will allow us to ensure that where there is model overlap, that it is rational and does not interfere with model objectives.”

Other priorities: “Our first pillar is to advance health equity by addressing the health disparities that underlie our health system,” CMS Administrator Chiquita Brooks-LaSure said in the webinar. “As the first African-American woman to lead CMS, I want to make sure that our programs are operating to reduce the health disparities that underlie our healthcare system, which were especially illuminated by the COVID-19 pandemic,” Brooks-LaSure noted. “At CMS, ‘how are we promoting health equity?’ will always be the first question we ask; never the last.”

CMS also noted that it wants to drive beneficiaries toward accountable care. “We envision a future by 2030 where every Medicare beneficiary and the vast majority of Medicaid beneficiaries are in an accountable care relationship,” Rawal said. “That could be through advance primary care or for example through an ACO. Regardless of the provider entity, we want to make sure that there is meaningful accountability for quality, measurement of outcomes that matter to patients, and management of total cost of care.”

And CMS has pledged to listen to providers and others affected by models. The agency is “going to engage our partners in the communities we serve through the policymaking and implementation process,” Brooks-LaSure assured attendees. “We are going to work to integrate the perspectives of CMS stakeholders … into our policymaking. We want to learn and hear feedback about our programs, especially from the people with lived experience.”

Hospice and related care is on the Innovation Center’s radar, too. “Areas that can be explored for greater integration with primary care include behavioral health, palliative care, and care for beneficiaries with complex needs and serious illness, where there is significant opportunity to improve care and outcomes while reducing overall costs,” CMS notes in its white paper.

Next: “Over the next months, we will be conducting listening sessions and continue to share our strategy with you all,” Rawal noted in the webinar.

Do this: “We encourage participants and potential participants in CMMI models to engage with CMS to provide input regarding your experiences, recommended changes to existing models, and any questions you have regarding CMMI strategic priorities,” say attorneys Jodi Daniel, Troy Barsky, and Janet Walker from law firm Crowell Moring’s Washington, D.C. office, in online analysis.

Note: Links to the white paper, a frequently asked question set, and more are at https://innovation.cms.gov/strategic-direction.