Kick your quality improvement plan into gear with VBP only 5 months away.
Whether you’re in one of the nine pilot states for Value-Based Purchasing or not, you have no time to waste when it comes to improving your outcomes.
Why? Superior outcomes are going to be the only thing standing between you and a possible payment penalty of up to 8 percent under the VBP model that the Centers for Medicare & Medicaid Services proposed in the 2016 home health prospective payment system proposed rule published in the July 10 Federal Register.
Recap: Under the proposal, all home health agencies in Massachusetts, Maryland, North Carolina, Florida, Washington state, Arizona, Iowa, Nebraska, and Tennessee will begin VBP on Jan. 1. CMS will “adjust” up to 5 percent of those agencies’
Medicare reimbursement for 2016 and 2017 outcomes; up to 6 percent for 2018; and up to 8 percent for 2019 and 2020. The adjustments based on 2016 outcomes would take effect in 2018 and so forth (see more details in Eli’s HCW, Vol. XXIV, No. 24). CMS will calculate the VBP scores based on 29 patient outcomes derived from OASIS, CAHPS, and claims.
Even if you aren’t in one of the nine pilot states (which may change in the final rule anyway), you need to get going on improving your outcomes, urges attorney Robert Markette Jr. with Hall Render in Indianapolis. You can expect CMS to move quickly on implementing VBP across the board, and your outcomes influence your star ratings on Home Health Compare, among other things.
Under the VBP model, CMS will determine whether you receive a penalty or bonus based on your scores as compared to your peers. And many of those peers have already been working on their outcomes for months, if not years.
“New kids on the block” will have to play catch-up, says financial expert Pat Laff with Laff Associates in Hilton Head Island, S.C.
Consider this advice to boost your outcomes, bolster your star rating, and safeguard your reimbursement:
One way to target areas for improvement is to look on Home Health Compare for those VBP outcomes where you perform the worst in relation to your peers. Another method is to look for a high percentage of claims downcodes, which could indicate poor communication between therapists and nurses, offered Laff Associates’ Lynda Laff and SHP’s Chris Attaya in a VBP presentation at the recent National Association for Home Care & Hospice Financial Management Conference in Nashville.
Laff and Attaya emphasized. Once it’s up and running, monitor for improvement, Jump says.
Pitfall: HHAs often send one or two staffers to OASIS education, then have them come back and teach the rest of the staff. Sometimes that works, but often it doesn’t, Pat Laff cautions. If your OASIS scores are suffering, you may need to invest in an OASIS trainer to furnish an in-service for all relevant personnel.
The best case scenario is to have therapists complete the OASIS for these items. But if that’s not possible, at least have therapists train nurses on how to code the OASIS items properly at admission, Pat Laff urges.
Requiring a nurse-therapist conference before submitting the OASIS is a surefire way to ensure accuracy, Pat Laff adds. But “it’s huge process change for most folks,” he admits.
You need to have competent staff in place who can get up to speed on OASIS, diagnosis coding, and other necessities.
Warning: This may mean eliminating poor performers, Lynda Laff and Attaya said in their presentation. Note: For more VBP preparation advice, see Lynda Laff and Attaya’s slides from their presentation at www.nahc.org/assets/1/7/FM15-403.pdf.
The 2016 HH PPS proposed rule is at www.gpo.gov/fdsys/pkg/FR-2015-07-10/pdf/2015-16790.pdf; comments are due Sept. 4. You can order a recording of Markette’s Eli-sponsored audioconferencereviewing the proposed rule at www.audioeducator.com/home-health/home-health-pps-2016-proposed-rule-07-13-2015.html.