Home Health & Hospice Week

Vaccination measures top most-hated list.

Home health agencies didn’t exactly greet the list of VBP measures with open arms. The Centers for Medicare & Medicaid Services proposed that the Value-Based Purchasing pilot slated to start Jan. 1 in nine states will use 29 measures (see box, p. 277). But many of those measures are flawed, said commenters on the HH PPS proposed rule that contained the VBP plan. Here are some of the most pressing problems bedeviling the proposed measures:

• Influenza Vaccination Coverage for Home Health Care Personnel: “Health care worker immunization rates now are reported to the CDC and to [CMS] as part of the inpatient quality reporting program, but the measure is not part of hospital VBP program,” pointed out BayCare HomeCare in Florida in its letter.

Such a measure makes vaccination virtually mandatory, noted Margaret Franckhauser, CEO of Central New Hampshire VNA & Hospice, in her letter. “There are some who cannot receive the vaccine, and a near mandate would pressure agencies not to hire such people.”

Plus: “This metric does not include consideration of the overall supply availability of staff vaccine at the local/state level regardless of known national declared shortages,” protested UnityPoint at Home in Iowa. “Regional availability limits should be reflected within the measure so as not to unduly penalize Home Health Agencies.”

Also, “the resources and time commitment required to be able to reliably report on this metric would create undue hardship for January 1, 2016 implementation,” UnityPoint said. If adopted at all, CMS should delay this item until 2017 and include it within OASIS for data collection, it urged.

• Herpes Zoster Vaccine (Shingles Vaccine) for Patients: “Zoster vaccine is very costly and is a part of the primary care system of care,” Franckhauser noted. “Agencies have no way of billing for zoster vaccine and would incur deep charges were it to be a quality requirement. We hold that it is a reasonable recommendation for primary care practitioners.”
• Care Management Types and Sources of Assistance (M2102): This measure “is not captured in Home Health Compare, and thus there are no national benchmarks,” said UnityPoint at Home in Iowa. In fact, CMS’s inclusion of M2102 “is perplexing,” noted the National Association for Home Care & Hospice. It “is used only as a risk adjustment factor and as part of a measure for the Potentially Avoidable Event — Discharge to community needing medication or wound assistance.” And agencies don’t even have all the information about this measure yet, adds Kindred at Home (which acquired Gentiva this year). “Kindred at Home recommends CMS specify the numerator and denominator for [M2102]. Currently, the rule lists ‘multiple data elements’ for this metric. Without specifying the data elements included in the numerator and denominator, it is unclear how to assess this metric.”

If CMS does want to keep M2102 on the list, the Alliance for Home Health Quality and Innovation asked CMS to treat it and M1900 like the four new measures in the “Total Performance Score” section, and score agencies only on whether they report data for the measures.

• Discharged to Community (M2420), Prior Functioning ADL/IADL (M1900): These aren’t currently reported in Home Health Compare, so agencies have no benchmarks for them, UnityPoint said.

Like M2102, M1900 currently is only used as a risk adjustment factor, NAHC noted. It’s not clear how CMS plans to use it as an outcome measure.

AHHIC “recommends that CMS provide an explanation as to the rationale for selecting and prioritizing these measures and ensure the measures are validated for home health performance measurement before agencies earn points for performance against them,” it said of M2102 and M1900.