Rural providers may get short end of the VBP stick.
Numerous commenters on the 2015 HH PPS rule voiced concerns or suggestions regarding the plan to designate five to eight states for the initial implementation phase of value-based purchasing.
The Illinois Hospital Association “recommends that [the Centers for Medicare & Medicaid Services] consider soliciting volunteer participation from all home health agencies across the country,” the trade group said in its comment letter on the proposed rule. CMS could set a first come, first serves maximum number of slots if it wished, IHA suggested.
“While testing the home health VBP program on a statewide basis has merit, CMS may obtain a more nationally representative demonstration by allowing individual agencies across the country to participate,” the Hospital & Healthsystem Association of Pennsylvania offered in its comment letter.
Rural concerns: And “while the hospital VBP program will be entering its third year … certain classifications of hospitals (principally small, rural hospitals) remain excluded, either for lack of patient volume in certain measures or by statute (critical access hospitals),” IHA added. “IHA suggests that CMS initially apply the same exclusions for the home health VBP demonstration that are applied in the hospital.”
“In rural states with Certificate of Need methodology, there are a limited number of home health agencies,” pointed out Partners in Home Care in Montana in its comment letter. “The distribution of quality scores in states [with] less than 50 agencies is very likely to be narrower than in states with several hundred to over a thousand agencies.”