Home Health & Hospice Week

Plus: VBP demonstration states want their 8% bonus for next year.

Home Health Value-Based Purchasing will bring many changes, including one related to a quality measure that bedevils home health agencies.

The Centers for Medicare & Medicaid Services’ 2022 home health proposed rule “proposes to replace the Acute Care Hospitalization During the First 60 Days of Home Health (NQF #0171) [quality] measure and Emergency Department Use Without Hospitalization During the First 60 Days of Home Health (NQF #0173) measure with the Home Health Within Stay Potentially Preventable measure” in 2023, CMS says in the rule published in the July 7 Federal Register.

“While both the ACH and ED Use measure are being proposed for removal under the HH [Quality Reporting Program], these measures are being proposed for inclusion in the expanded HHVBP Model beginning with the CY 2022 performance year,” CMS explains. “We seek public comment on whether we should instead align the expanded HHVBP Model with the proposed changes for HH QRP by proposing to remove the same two measures from the expanded Model in a future year.”

What that means for VBP: HHAs could have their payment adjustments for their 2023 year, which would affect 2025 rates, based on the brand-new HH Within Stay Potentially Preventable measure.

The National Association for Home Care & Hospice “supports aligning the measures in the HHVBP program with the measures reported in the HH QRP,” NAHC says in its comment letter. “However, CMS should give HHAs ample time to become familiar with the Home Health Within Stay Potentially Preventable Hospitalization measure, and to affect outcomes, if needed, before including it in the HHVBP program.”

The delay should be at least a year, suggests the Home Care Alliance of Massachusetts' Patricia Kelleher in her comments.

Plus: CMS should exclude observation stays from the measure. “Observation stays function more as an extension of an emergency department stay rather than an alternative to an inpatient stay,” NAHC offers. And there are “several drivers of emergency department use outside the control of an HHA. Furthermore, hospital policies vary on when to admit a patient to observation vs. discharge to home,” NAHC concludes in its comment letter.

Other VBP concerns frequently raised by commenters include:

• Burden. Because the data reporting for VBP will come from already collected sources, CMS says “there would be no additional burden” for HHAs. But of course, the program comes with quite a bit of extra work, insists Josh Lamkin, senior analyst with Medical Information Technology Inc. “We recognize the cost saving success of the HHVBP pilot program, and we do support the program’s proposed expansion,” Lamkin says in his comment letter. “However … the administrative burden the HHVBP program places on agencies remains a concern. Despite the fact that measure data for the expanded program would be captured from claims, OASIS, and CAHPS data that is already being submitted by agencies, agencies face a significant workload analyzing data and monitoring performance,” he tells CMS.

• Last-year payments. When it began the VBP demonstration, CMS told HHAs it would adjust payments by up to 8 percent for the last year of the demo, 2022. In proposing that the expanded VBP model begin in 2022, CMS wants to cancel that last demo year — and not pay demo agencies for it. “The proposal to institute an early end to the original HHVBP raises questions of fairness,” Kelleher maintains in her letter. “Our member HHAs bore the costs and burdens of performance improvement actions with a promise of eligibility for a performance bonus as high as 8 percent. CMS’ proposal to retroactively end the program has the appearance of allowing Medicare to get the benefit of our member HHAs’ quality improvement performance without having to keep up its end of the bargain to reward high performing providers,” she criticizes.

• Benchmarking reports. In the proposed rule, CMS proposes to furnish “HHAs with their applicable benchmarks and achievement thresholds prior to the start of or during the performance year so that they can be used to set performance targets to guide HHAs’ quality improvement projects,” the rule says. But the Annual TPS and Payment Adjustment Report “would be made available to each of the competing HHAs in approximately August of each year preceding the payment adjustment year, expected beginning in August 2023” — before the second year of VBP. “Given the aggressive timeline of January 2022 implementation we are not confident that CMS will be able to provide organizational baseline and benchmarks to providers,” worries UPMC Home Healthcare President Paula Thomas in her comment letter.

• Public reporting. “For each HHA that qualified for a payment adjustment based on data for the applicable performance year,” CMS plans to publicly report by about December 2023 the HHA’s TPS; the HHA’s TPS Percentile Ranking; and the HHA’s payment adjustment for a given year, notes Humana’s Joy Cameron. “We are concerned about lack of consistency between HHVBP TPS and the star rating system,” Cameron tells CMS. “A 5-star HHA could have a lower TPS and a 3-star HHA could have a higher TPS because there is no direct correlation between the two scoring methodologies. This is confusing to patients and staff who do not understand the scoring intricacies of the two programs.” CMS should “try to make these programs as comparable as possible,” Cameron urges.