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Home Health & Hospice Week

Regulations:

What’s Coming For VBP In The 2023 Home Health Rule?

Published on Fri May 13, 2022

Providers dearly hope for a delay, but that’s unlikely, experts agree.

There’s still time for Medicare officials to make changes to VBP — but will they?

Background: The Centers for Medicare & Medicaid Services usually issues the home health proposed payment rule for the following fiscal year by July 4, if not earlier. This year, the regulation likely will be the last rulemaking vehicle for CMS to make changes to the first performance year of Home Health Value-Based Purchasing.

Keep in mind, the rule could come days or even weeks ahead of the usual time, like the hospice proposed rule did this year (see HCW by AAPC, Vol. XXXI, No. 12).

Home health agencies have lots of questions about how VBP works and what its impact on them will be, both operationally and financially. And what they’d most like to see is more time to figure that all out.

The clients of consultant Pam Warmack with Clinic Connections in Ruston, Louisiana, are “primarily small companies,” Warmack tells AAPC. They “would like to see major programs delayed,” including VBP, she stresses. “They are still reeling from staffing shortages and the negative impact COVID has had on their businesses. There is not a lot of ‘profit money’ lying around to spend on extra products or training opportunities,” Warmack maintains.

Just a one-year delay would be appreciated, says consultant Linda Scott of Scott Solutions in Arlington, Virginia. But Scott is “not at all hopeful,” she laments.

“I feel like it is a done deal,” Warmack says of VBP’s Jan. 1, 2023 implementation date for its first performance year. “Since we seem to be moving out of COVID-19, I think CMS will surge ahead with its plans for what it wants done,” she adds. CMS has already pulled back some COVID-19 public health emergency blanket waivers, including some for inpatient hospice facilities (see story, p. 134).

But then again, the Medicare agency is notoriously unpredictable. “It’s CMS,” notes consultant Angela Huff with BKD in Springfield, Missouri. “Anything is possible.”

Nevertheless, wise HHAs will move ahead with preparations. “You don’t have to think the sky is falling,” advises attorney Robert Markette Jr. with Hall Render in Indianapolis. “But keep on top of it,” Markette urges.

Bottom line: “Prepare like you did for PDGM,” Mar-kette counsels.

Will Staggered PPH Implementation Hold?

A change that may be a bit more likely is modifying the measures used for VBP.

“I’m keeping my eye on PPH,” shares Sherri Parson with consulting firm McBee. PPH is the forthcoming Home Health Within Stay Potentially Preventable Hospitalization (PPH) measure.

Reminder: In its 2022 home health final rule, CMS finalized that the PPH measure will replace the Acute Care Hospitalization and Emergency Department measures in the HH Quality Reporting Program effective January 2023 (see HCW by AAPC, Vol. XXX, No. 40-41). HHAs will get confidential preview reports with data on the new measure in October 2022, a CMS official said in the November 2021 Home Health Open Door Forum.

While HHQRP implementation is set for next year, VBP still has the ACH and ED measures in place for that timeframe. In the forthcoming proposed rule, PPH “might be slipped in … adding it to VBP January 1, 2023 as it is with the Quality Reporting Program beginning January 2023,” Parson suspects. v

Note: Stay tuned for upcoming home health rule coverage from Home Care Week by AAPC.

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