Home Health & Hospice Week

TNC numbers appear on track for an update.

VBP data just keeps rolling in. To keep from sinking under its weight, smart home health agencies will learn how to swim in Interim Performance Report waters.

The Centers for Medicare & Medicaid Services just finalized its October IPR figures last month, after considering correction requests (see HHHW by AAPC, Vol. XXXII, No. 45). But the January IPR will be in HHA’s iQIES folders “in the next week and a half or so,” CMS’ Marcie O’Reilly said in the agency’s Jan. 10 Home Health Open Door Forum.

Reminder: “The expanded HHVBP Model quarterly Interim Performance Reports (IPRs) provide HHAs with information on their measure performance in the expanded Model, based on the 12 most recent months of data available,” CMS explains in its VBP materials. “The IPR provides feedback to HHAs about performance relative to quality measure achievement thresholds, benchmarks, and improvement thresholds,” it says.

That can help agencies gauge where they will fall on the plus-or-minus 5 percent reimbursement continuum for VBP impacts. And for HHAs that pay attention early enough and course correct, it can help them focus improvement efforts on risk areas.

Do this: “We encourage those that have not been accessing IPRs to do so, and access each quarterly report as soon as they are released,” O’Reilly urged forum attendees.

Agencies can get help understanding their IPRs and learning how to use them with CMS’ archived webinar on the topic from July 2023, O’Reilly highlighted. The recording, slide deck, and a related question-and-answer document are under the “Model Reports” section at www.cms.gov/priorities/innovation/innovation-models/expanded-home-health-value-based-purchasing-model.

Meanwhile, no news may be good news on HHAs receiving updated TNC figures in the January IPRs.

Recap: CMS froze the data for the Total Normalized Composite (TNC) Change in Mobility and TNC Change in Self-Care measures for the October 2023 IPRs “due to unforeseen circumstances,” the agency said in its October HHVBP newsletter. But “CMS anticipates returning to a normal reporting schedule for the January 2024 IPRs,” the agency assured at the time.

By the way, those unforeseen circumstances were “a major update to iQIES in mid-April [that] impacted production of the Total Normalized Composite (TNC) measures,” CMS revealed in its December VBP frequently asked question set.

CMS reiterated in new FAQ Q6028 that “this issue will be resolved for future IPRs and will not impact the final [Total Performance Score] for the calendar year (CY) 2023 performance year, which will appear in the August 2024 APR,” according to the FAQs at www.cms.gov/priorities/innovation/media/document/hhvbp-exp-faqs.

O’Reilly didn’t have a confirmed update on the TNC status in the forthcoming reports, she said.

It’s The Last Year For TNC Measures

Don’t forget, TNC numbers could prove crucial in whether you will see positive payment adjustments in 2026, based on 2024 data. That's because they account for 17.5 percent of an agency’s VBP score in the larger-volume cohort and 25 percent in the smaller-volume cohort (see weighting details in HHHW by AAPC, Vol. XXXII, No. 39-40). But HHAs will be saying goodbye to the TNC measures altogether in 2025, thanks to significant VBP changes CMS finalized in the 2024 home health final rule.

Instead: Starting in January 2025, CMS will use the Discharge Function measure for 20 percent (larger cohort) and 28.751 percent (smaller cohort) of agencies’ VBP scores. CMS rebuffed rule commenters’ criticisms of the change, noting in the rule that “we selected this weight because of our belief that function is critical for beneficiaries to safely remain in their home” and it’s “an important quality measure that should have the weight that it has in the expanded Model.”

Critics say basing the measure on Impact Act-required GG items, which are the same across post-acute care settings and relatively new to home health, makes the measure far from ideal for VBP purposes.

Note: CMS’ VBP website is at www.cms.gov/priorities/innovation/innovation-models/expanded-home-health-value-based-purchasing-model. The VBP changes are in the 205-page final rule at www.govinfo.gov/content/pkg/FR-2023-11-13/pdf/2023-24455.pdf.