Home Health & Hospice Week

Waiting for rulemaking could cut 8 percent off your payments.

You don’t have time to waste when it comes to getting your quality measures in good enough shape to ward off payment penalties.

The Centers for Medicare & Medicaid Services plans to implement a "value-based purchasing" program, formerly known as pay for performance, for home health agencies in up to eight states in 2016. CMS expects to reward or penalize agencies from 5 to 8 percent based on their performance with as-yet-named outcome measures, according to the 2015 HH PPS final rule (see Eli’s HCW, Vol. XXIII, No. 40).

CMS hasn’t specified which outcomes it will use in the VBP program -- that will come in rule-making expected later this year. But you shouldn’t wait around to see which ones CMS chooses, urges financial consultant Pat Laff with Laff Associates in Hilton Head Island, S.C.

"Agencies have to be dealing with this now," Laff says of quality measure improvement.

VBP Program Details Should Emerge In 2015

It’s important to get going on quality measure improvement right away to minimize risk under forthcoming VBP. Remember, the potential 8 percent penalty may come on top of sequestration cuts, rebasing reductions, and more.

But some planning details will have to wait until agencies know more about the program. Watch for these details in upcoming rulemaking, Laff says:

• specific thresholds for the reward group, the penalty group, and the "neutrality band" that receives neither rewards nor penalties;
• specific measures used to determine VBP payments;
• states or other areas affected;
• percentage of payments at risk under VBP;
• methodology for withholding payments for the reward/penalty pool, based on budget neutrality.