Home Health & Hospice Week

Participants get timeline for benchmarks.

Home health agencies anxious to figure out how they are stacking up to their peers under the new Value-Based Purchasing model will get some clues soon, but more information as the year goes on. So says the Centers for Medicare & Medicaid Services in a new question-and-answer set on the program, which launched in nine states this month.

Reminder: As of this month, CMS is comparing all agencies in the nine VBP states (Massachusetts, Maryland, North Carolina, Florida, Washington, Arizona, Iowa, Nebraska, and Tennessee) on 24 quality measures. Agencies’ results will affect whether they get a penalty, stay even, or receive a reward in their 2018 payments. HHAs will start out with up to 3 percent of their payments at risk, increasing to 8 percent by 2022.

HHAs in VBP states have protested that they are starting the model nearly blind, missing crucial details on measure calculations and lacking benchmarking information (see Eli’s HCW, Vol. XXIV, No. 44).

Now VBP agencies at least have a timeline for receiving vital benchmarking data.

First: In conjunction with a VBP webinar “tentatively” scheduled for this month, CMS will release “preliminary aggregate level benchmarks and achievement thresholds for the OASIS, HHCAHPS and Claims measures based on data for 2013 and 2014,” it says in the Q&A.

Second: In April, CMS will provide current benchmarks and achievement thresholds for the OASIS measures, it says in another Q&A.

Third: By July, benchmarks and achievement thresholds for the HHCAHPS measures and the claims measures will be available, CMS adds.

Agencies won’t start reporting data on the New Measures (Influenza Vaccination Coverage for Home Health Care Personnel; Herpes zoster [Shingles] vaccination; Advanced Care Plan) until October (for the July-October period), so benchmarks for those presumably will be available later. But the new HHVBP Secure Portal will be available to agencies in March, in time for the first quarterly benchmark report, CMS notes.

Despite the later date for data submission via the new HH VBP Secure Portal, “it is important that HHAs register for the HHVBP Secure Portal now,” CMS stresses.

VBP Calculations To Use Medicaid, Managed Care Patients’Data

In the 2016 HH PPS final rule, CMS said that under the VBP model, “a competing HHA is only measured on performance for care delivered to Medicare beneficiaries within boundaries of selected states and only payments for HHA services provided to Medicare beneficiaries within boundaries of selected states will be subject to adjustment under this model unless a reciprocal agreement is in place.” So on the eve of implementation, agencies in VBP states were wondering whether that meant Medicare FFS only, or also Medicare Advantage.

But in the new Q&A, CMS says that “the OASIS-based measures are calculated using … OASIS assessments from Medicare FFS, Medicare Advantage, Medicaid FFS, and Medicaid Managed care.” Likewise, for the CAHPS measures, “HHCAHPS surveys from all the beneficiaries for which a HHA provides services are included in the model,”

CMS reveals in another Q&A. “All patients 18 years old and older who are covered by Medicare or Medicaid who meet other survey criteria are eligible to be included in the HHCAHPS Survey. This includes patients who are enrolled in Medicare feefor- service plans and those enrolled in Medicare Advantage (MA) plans or Medicaid managed care health plans.”

Exception: “The claims-based measures are only based on the Medicare FFS population since the measures are only derived from Medicare claims,” CMS says in another Q&A. CMS’s inclusion of Medicaid beneficiaries’ data “is in conflict with the standard set out in the HHVBP rule that limits the data used to Medicare enrolled,” notes the National Association for Home Care & Hospice in its member newsletter.

CMS does maintain that “the measures are risk adjusted to include risk factor elements like the payer for the episode (Medicare/Medicaid/Managed Care) as well as other risk factors selected using a rigorous, multi-step process that includes clinical review of the scientifically identified risk factors.”

Note: See the Q&As at https://innovation.cms.gov/initiatives/Home-Health-Value-Based-Purchasing-Model/faq.html.