Home Health & Hospice Week

ICD-10 and other regulatory pressures create overwhelming burden.

If home health agencies had only Value-Based Purchasing to focus on, maybe they could manage the 29 quality measures and huge risk pool involved in the proposed program with almost no prep time. But the VBP pilot is only one of a myriad of regulatory requirements they’re juggling.

So said numerous providers and industry reps offering comments on the 2016 Home Health Prospective Payment System proposed rule, issued by the Centers for Medicare & Medicaid Services in July.

Home health agencies already are facing extreme financial and operational pressures, providers told CMS. VBP is coming “at a time when ICD-10 coding will reduce efficiency and cost agencies precious dollars as the learning curve unfolds,” warned Tallahassee Memorial Home Health Care in its comment letter.

HHAs continue to struggle with confusing face-to-face physician encounter requirements, others added. Plus, “the Home Health industry will just be entering the 3rd year of Rebasing,” noted Innovative Financial Solutions for Home Health in its comment letter.

“The VBP pilot timing coincides with continued reimbursement reductions through case mix weight reductions and Medicare sequestration,” said the Association for Home & Hospice Care for North Carolina in its comment letter. “The decreasing reimbursement climate combined with the unknown impact of VBP will be potentially devastating to our agencies.”

Florida agencies are also facing another demonstration — the Comprehensive Care for Joint Replacement Payment Model for Acute Care Hospitals Furnishing Lower Extremity Joint Replacement Services. “Forcing HHAs to have to participate in both demonstrations simultaneously beginning on Jan 1, 2016, while having significant portions of the country excluded from both could be ... extremely harsh and would quite likely skew the results of both demonstrations in those areas of overlap,” Innovative maintained.

Multiple Florida commenters noted the unfairness of the double demo. “Reasonableness would dictate that any demonstrations should be designed such that any HHAs ... would only have to participate in one demonstration at a time to give that demonstration an opportunity to establish without bias what the actual results of that demonstration would be,” Innovative said. “To force any HHAs to have to endure all this and more, as well as have to be involved in two separate demonstrations that begin on Jan. 1, 2016, would seem unreasonable and punitive in nature.”

Give Agencies A Year To Prepare, Trade Group Urges

Even without the added pressures of ICD-10, the joint replacement demo, and more, the timeline is just not realistic, many commenters said.

HHAs in the pilot states — which may change from the proposed rule — would have only about 60 days from the final rule “to take all the steps needed to make VBP a success for the organization (or to avoid the financial disaster that could occur),” the National Association for Home Care & Hospice criticized in its comment letter. CMS did offer some elements of the VBP plan in its 2015 HH PPS rule. But “that program description did not include the measures that CMS would employ or the ... affected states,” NAHC notes. “Without that information, HHAs had no way to properly prepare for HHVBP.”

Recommendation: “Any HHVBP program should provide a reasonable lead time for affected providers to adjust their practices to maximize operational improvements and patient outcomes,” NAHC urges CMS in the letter. “A minimum of 6 months to a year is necessary to achieve those ends.”