Home Health & Hospice Week

2020 data won’t be good for VBP decision-making.

In addition to OASIS-E and NPPs, the new COVID-19 Interim Final Rule also addresses the Home Health Value-Based Purchasing Model.

The Centers for Medicare & Medicaid Services is “implementing a policy to align the [HHVBP] Model data submission requirements with any exceptions or extensions granted for purposes of the Home Health Quality Reporting Program (HH QRP) during the PHE for COVID-19,” CMS says in the Interim Final Rule published in the May 8 Federal Register.“We are also implementing a policy for granting exceptions to the New Measures data reporting requirements under the HHVBP Model during the PHE for COVID-19.”

Specifically, “to the extent that the data that participating HHAs in the nine HHVBP Model states are required to report are the same data that those HHAs are also required to report for the HH QRP, HHAs are required to report those data for the HHVBP Model in the same time, form and manner that HHAs are required to report those data for the HH QRP,” CMS says in the rule. And “if CMS grants an exception or extension that either excepts HHAs from reporting certain quality data altogether, or otherwise extends the deadlines by which HHAs must report those data, the same exceptions and/or extensions apply to the submission of those same data for the HHVBP Model,” the rule mandates.

CMS has already excepted HHAs from reporting HH QRP data in three quarters: Oct.1, 2019 – Dec.31, 2019 (Q4 2019); Jan.1, 2020 – March 31, 2020 (Q1 2020); and April 1, 2020 – June 30, 2020 (Q2 2020) (see Eli’s HCW, Vol. XXIX, No. 14). It will do the same for VBP states, it says.“We do not anticipate any issues in calculating the TPSs based on CY 2019 data under the HHVBP Model because HHAs had the opportunity to submit these Q4 2019 data on a rolling basis,” the rule adds.

Plus: CMS is granting an exception to HHVBP Model agencies for two new measure periods: April 2020 (data collection period Oct.1, 2019 – March 31, 2020) and July 2020 (data collection period April 1, 2020 – June 30, 2020).“HHAs may optionally submit part or all of these data by the applicable submission deadlines,” the rule offers.

Stay tuned: “We are evaluating possible changes to our payment methodologies for CY 2022 in light of this more limited data,” CMS adds. That might include using “a different weighting methodology given that we may have sufficient data for some measures and not others.” Public reporting of CY 2020 performance year data could also change, the rule says.

Adopting changes could be a good idea.“We are very supportive of the HHVBP demo,” the National Association for Home Care & Hospice says in a release.“However, there has been a massive change in case-mix and clinical practice while addressing the pandemic. As a performance year, 2020 would not be a good time to learn about how financial incentives and penalties impact patient outcomes.”

Note: The Interim Final Rule is at www.cms.gov/files/document/covid-final-ifc.pdf.