Home Health & Hospice Week

Social determinants of health vary by geography.

If you think a national cohort for the upcoming Home Health Value-Based Purchasing payment model will be bad news, you’re not alone.

Many commenters on the 2022 home health proposed rule feel the same way, judging from the over-200 comment letters submitted to the Centers for Medicare & Medicaid Services on the rule.

Under the VBP demonstration that has run four years in nine states, CMS has grouped HHAs into cohorts based on their state. In the proposed rule, CMS says it wants to group HHAs into national cohorts based on size, with most agencies falling into the “larger” category.

“We are concerned about geographic variation, especially with the proposed weighting of the 60-day acute care hospital­ization measure, which is worth at least 26.25 percent of the Total Performance Score (TPS),” says Joy Cameron, associate vice president of public policy with Humana, in her comment letter. “For example, the hospitalization rate in WV is 18.9 percent compared the nationwide average of 15.4 percent. This inherently puts those HHAs in WV at a disadvantage for attaining achievement thresholds,” Cameron maintains.

“Given the high variability in home health utilization across the country and how this utilization is impacted by regional differences in social determinants of health, as well as differences in state investments in the health of communities, we believe that further analysis of the proposed cohorts is warranted,” insists Patricia Kelleher with the Home Care Alliance of Massachusetts in her comment letter. Reconfiguring the cohorts would “avoid unintended consequences for equity in access to care across the country,” Kelleher tells CMS.

“Cohorts under the nationwide model would differ significantly from the original model,” highlights Laura Friend with the West Virginia Council of Home Care Agencies. “CMS’ proposal for the nationwide model has the potential to significantly shift resources across state lines, potentially depriving regions of funding for critical home health services,” Friend cautions.

“We … urge CMS to consider creative methods by which to peer group cohorts by population characteristics as well as recognizing access to home health services (e.g., the number of HHAs) within a service area,” suggest execs Margaret VanOosten, Jenn Ofelt, and Cathy Simmons with UnityPoint at Home based in Iowa.

Many commenters recommended that CMS stick with the state-based structure.