If you're wondering how you stack up to your peers, you're not alone. Thousands of home health agencies are subscribing to benchmarking services, working among peer groups and using government reports to benchmark data. Benchmarking statistics let participants in on trends and broad results that allow HHAs to get a feel for how they're doing, says consultant Beth Carpenter with Lake Barrington, IL-based Beth Carpenter and Associates. Agencies that fail to gather comparison information "are headed for serious trouble," Carpenter predicts. She recommends collecting and comparing general stats regularly. Influential bodies from the Medicare Payment Advisory Commission to the HHS Office of Inspector General have raised the spectre of underutilization as a result of the home health prospective payment system. Check your visit data against these figures collected by Seattle-based benchmarking company Outcome Concept Systems Inc. for 10 regions to see if you might be sending up red flags for this serious fraud and abuse risk (see chart,). Data collected from more than 1,000 agencies in all 50 states for the second quarter of 2002 showed the national visit average at 20 per patient, according to OCS' 2002 State of the Industry Report. HHAs furnished about nine skilled nursing visits, seven therapy visits and four aide visits per patient, OCS notes in the report. The Centers for Medicare & Medicaid Services has indicated it plans to crack down on underutilization now that HHAs have gotten used to - and perhaps figured out how to game - the new payment system. Agencies whose visits have remained consistent with pre-PPS patterns should have nothing to worry about from regulators, assures consultant Terri Ayer with Ayer Associates in Annandale, VA. And the feds will expect responses to the incentives of PPS, adds Ayer, who sees the last few years as a planned transition period. But HHAs whose visit figures have migrated wildly or culminated in a dramatic profit may be viewed skeptically by regulators, experts warn. Comparison to all Medicare-certified HHAs' visit figures, available only through the government, is the best way to gauge your performance, notes Carpenter. But CMS' extremely slow release of data to benchmark against means HHAs must rely on private companies or their own collective efforts to compare as best they can in the interim. Surveyors, who will in large part lead the crusade against underutilization, will be armed with government statistics, Carpenter points out. The OCS report also compares visits by discipline for agencies in four categories: small, small-medium, medium-large and large. Therapy use almost doubled from the smallest agencies at an average of four therapy visits to the largest agencies at an average of seven therapy visits. Ranges for skilled nursing and aide visits were more uniform over the size categories. Availability of therapy staff may play a part in that difference, Ayer suspects. Larger HHAs have the resources and the patient volume to keep therapists on staff full time. In contrast, smaller agencies' need for therapists will fluctuate. Smaller agencies also often are located in more rural areas, where there is a dearth of therapists. And larger agencies often have the wherewithal to offer more comprehensive benefit packages to attract therapists, Ayer contends. The more the larger agencies handle therapy cases, the more they receive referrals for those types of cases, creating a cycle that increases their therapy utilization. Larger HHAs also tend to attract more complex patients because of their high-tech capabilities and their wider variety of specialty programs, Ayer argues. More complex patients often need more therapy. The OCS report finds only slight differences in visit patterns for hospital-based versus non hospital-based agencies and not-for-profit versus proprietary HHAs. While comparing one's performance to these benchmarks can be very useful, experts remind agencies to keep certain caveats in mind. First, the HHAs that pay for benchmarking services are not a random sample of providers. It's likely they are more interested in improving patient outcomes than the average agency, Ayer points out. For that reason, she suspects they may provide more visits than is typical of the entire Medicare population. Also, OCS' utilization figures aren't limited to Medicare patients only and span a patient's entire length of stay, even if it encompasses multiple PPS episodes. And when making comparisons within a region, HHAs should realize there may be big differences between states, and regulators are likely to have at least state-level data when they look for outliers, Ayer adds.