Home Health & Hospice Week

Plus: VBP, Care Compare, CAHPS addressed in forum.

The clock is ticking down to the May 31 expiration date for the Review Choice Demonstration project, but Medicare officials remain silent about its fate.

Recap: The Centers for Medicare & Medicaid Services originally planned a Pre-Claim Review demonstration project to begin in Illinois in August 2016 and spread to four other states. But amid major backlash, PCR was paused in Illinois and called off on the eve of its implementation in Florida in April 2017. CMS then re-proposed the project under the RCD name in 2018, swapping out two states. It reimplemented the retooled program in Illinois in June 2019, then followed with Ohio in September 2019 and Texas in March 2020. Florida and North Carolina were supposed to start RCD in May 2020, but the COVID-19 public health emergency postponed that, with the phase-in period for those two states starting in August 2020 and stretching until September 2021. Last December, CMS expanded RCD to a new, sixth state — Oklahoma.

CMS has always said RCD was supposed to be a five-year pilot project. “The demonstration will end in all states on May 31, 2024,” CMS confirmed in a question-and-answer set last updated in August 2022.

For many months, home health agencies and their representatives have been asking about the program’s fate. And for months, CMS has been staying silent on the matter.

In an Oct. 11, 2023 Home Health Open Door Forum, a CMS official did say that “CMS is currently working internally to determine if the demonstration will be extended past that May expiration date.” If CMS decided to extend, “we will definitely provide ample notice,” she pledged at the time (see HHHW by AAPC, Vol. XXXII, No. 37).

In the most recent April 5 Forum, CMS said it didn’t have anyone in the Zoom session to answer a question on the matter. The agency hasn’t responded to a similar question from AAPC.

In its most recent Home Health and Hospice Coalition Questions and Answers posted on March 20, HHH Medicare Administrative Contractor Palmetto GBA says “we have no further instructions at this time” on the program’s extension. “The Home Health Review Choice Demonstration is set to end on May 31, 2024,” it adds.

Industry experts remain skeptical that CMS will give up this review program, they tell AAPC. That means agencies should stay tuned for a potential eleventh-hour renewal.

Resources: The RCD FAQs are at www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Review-Choice-Demonstration/Downloads/RCD-FAQs.pdf and Palmetto’s Coalition Q&As are at www.palmettogba.com/palmetto/jmhhh.nsf/DID/Q5F9S3CM6V.

Other home health issues addressed in the forum include:

• VBP. Look for your next Interim Performance Report for Home Health Value-Based Purchasing to land in your iQIES folders on or about April 26, CMS’ Marcie O’Reilly said in the forum. “We encourage the many HHAs that have not been accessing their IPRs to do so, and for all HHAs to access their quarterly reports as soon as they are released,” O’Reilly told attendees.

The next IPR, in July, will include an extra tab for the measure set that starts in 2025, O’Reilly added.

Meanwhile, the first Annual Performance Report will be coming to you in August, O’Reilly reported. It will contain both your Total Performance Score and associated payment adjustment, she reminded. At that time, CMS will provide a webinar reviewing the reports and the associated public reporting.

• Care Compare. CMS will refresh home health data on Care Compare this month, CMS’ Jermama Keys noted. Agencies received preview reports for the data in January.

New preview reports for the July refresh also are now in HHAs’ iQIES folders, CMS says in a message to providers.