Home Health & Hospice Week

Tip: Check out the newest educational video from CMS.

There’s no time to waste in preparing for the Expanded Home Health Value-Based Purchasing payment model that is going nationwide — and up to 5 percent of your original Medicare reimbursement depends on it.

Recap: Home health agencies are currently in the “pre-implementation year” of VBP, with data collection starting in January for payment adjustments applied in 2025. The Centers for Medicare & Medicaid Services is educating HHAs on the payment model all year, and urging agencies to undertake their own preparations for it (see HCW, Vol. XXXI, No. 14).

HHAs that want to get serious about avoiding an up-to-5 percent penalty — and maybe even attaining an up-to-5 percent bonus — have a mountain of preparation ahead of them in the remaining months of 2022.

Heed this expert advice from industry veterans on how to survive — and thrive — under VBP:

1. Watch for CMS issuances. “During 2022, CMS will provide education and support to competing home health agencies, allowing time to prepare for implementation of the expanded model,” said CMS’ Marcie O’Reilly an “HHVBP Model Expansion 101” webinar in February. “Home health agencies can use this time to assess their own performance,” recommended O’Reilly, acting program coordinator for the Expanded HHVBP Model.

CMS plans to issue educational materials that will assist agencies is prepping all year long. That includes benchmarks in mid-May; sample interim performance reports and sample annual reports in late July; a model implementation guide and guide specific to quality measures; updated materials related to the two composite measures; and educational videos and webinars, O’Reilly told attendees of CMS’ April 20 Home Health Open Door Forum.

Those new resources will supplement the materials CMS already has posted on its expanded VBP webpage, which include frequently asked questions, newsletters, technical documents, and the February webinar.

New: On April 29, CMS also issued a “Quality Measures Used in the Expanded HHVBP Model” on-demand video, which “provides measure-specific information on each of the quality measures included in the expanded Model,” the agency says. The video is accompanied by a How to use Existing Quality Assurance and Performance Improvement (QAPI) Processes to Support Improvement in Expanded Home Health Value-Based Purchasing (HHVBP) Model paper, which “provides a practical and visual guide to the quality improvement cycle,” CMS says. “This resource also highlights data and reports currently available to HHAs in iQIES and on the Care Compare website,” the agency adds.

2. Start right now. With so many priorities on their plates and payment adjustments not hitting until 2025, HHAs may be tempted to push off VBP prep for a little while. Don’t fall into that trap, experts warn.

Agencies need to look at their performance immediately and “figure out where you’re at,” urges attorney Robert Markette Jr. with Hall Render in Indianapolis. “The time to figure that out is not the last lap of the race,” Markette stresses.

“You really want to avoid being in the bottom half ” and undergoing a pay reduction, Markette emphasizes. “It would be nice to get a bonus, but you really have to avoid penalties.”

While some agencies are diving into VBP prep, many haven’t started yet, observes consultant Angela Huff with BKD in Springfield, Missouri. “I took an informal survey of a group of 125 agencies last week, and only two had started preparations,” Huff tells AAPC. “Agencies are not going to be able to wait until the last minute and be successful,” she warns. “I am concerned that agencies will wait too late and not be ready come Jan. 1.”

HHAs “should be taking advantage of every learning opportunity out there,” exhorts consultant Pam Warmack with Clinic Connections in Ruston, Louisiana.

Given VBP’s complexity, taking it on may seem overwhelming. But “it is digestible if you break the elements of VBP down and focus,” Huff assures.

3. Learn the VBP ropes. You can’t succeed under VBP if you don’t understand the new model. HHAs must start with a “basic understanding of how this works,” advises consultant Linda Scott of Scott Solutions in Arlington, Virginia. For example, “understand what improvement and achievement are” in VBP, Scott offers.

“How can they work on navigating a program successfully if they don’t understand the program?” Warmack points out.

“Very little of the content is new,” Scott reassures agencies. “It is just more complex math, to me,” she says. “We have some bits from HHCAHPS, some from quality indicators — both of which we are quite familiar with by now,” Scott continues. “Then they are combined with some new things for new measures that we calculate in different ways, and we look at value from two different perspectives,” she summarizes.

4. Know your data. One of the first steps in VBP readiness is understanding where you stand. “Get better with your data,” urges Scott, who worked with agencies under the preliminary model in Maryland. “Figure out your baseline,” she advises.

Whether you’ll aim to compete in the improvement or achievement areas, you’ll need to know where you’re starting.

“Providers need to study their performance now,” War-mack judges.

Many HHAs wish CMS would go ahead and give them their data and standings compared to their VBP peers, notes reimbursement expert M. Aaron Little, also with BKD. “The typical agency is hungry to see their specific data,” Little says. “The lack of data today isn’t stopping agencies from trying to prepare, but I think preparation now would be much more meaningful if all agencies could see their specific baseline year performance today as measured within their assigned cohort,” Little notes.

Because that data doesn’t appear to be coming from CMS any time soon, HHAs must produce and examine their own data.

5. Check with vendors. Chasing down data may mean changing your relationship with your vendor, or finding a new one. “I would hope that software vendors will duplicate the [VBP] calculations in their programs,” says Julianne Haydel with Haydel Consulting Services and The Coders in Baton Rouge, Louisiana.

Agencies “should be having conversations with their software vendors about how data can be collected and analyzed to prepare them for what is to come,” Warmack recommends. “They should already be shopping for a data analytics software as well,” she adds.

6. ID your focus areas for improvement and build your improvement plan. HHAs don’t have the resources to tackle everything at once, experts observe. A number of factors will go into choosing your areas for improvement and formulating a plan to actually achieve better results (see story, p. 123). How successful you are will make or break your reimbursement under VBP.

7. Don’t delay initiating improvements. HHAs may be ready to begin learning about VBP, securing important data, and identifying weak spots that are ripe for improvement. But VBP preparations shouldn’t stop there.

“There are some misconceptions that if agencies don’t begin today, they will fare better when VBP begins,” Parson notes. “What they don’t realize is that performance will be compared to their baseline year — for most of us 2019 — so beginning today can only help organizations to get a head start on performance now,” she points out.

In other words, if you wait until January 2023 to start your improvement efforts for VBP, the agencies you are competing against in your cohort will be months ahead of you for achievement bonuses, and you will have shorted yourself months to obtain higher improvement scores.

“Agencies are not going to be able to wait until the last minute and be successful,” Huff warns. “It’s going to be a lot like a marathon run with VBP in 2023, and the race starts Jan. 1. When do you start training for a marathon? Certainly well before race day, and agencies that show up late to train may not see the outcomes that they want,” she stresses.

“Trying to move the needle on outcomes does not happen overnight,” Little cautions. “It takes time, and the time is now.”

8. Use CMS data to help with ACH, ED measures. If you want to get a lot of bang for your improvement buck by tackling the ACH and ED claims-based measures, a good place to start is with the supporting information for the forthcoming Home Health Within Stay Potentially Preventable Hospitalization (PPH) measure.

Reminder: In its 2022 final rule, CMS finalized that the PPH measure will replace the ACH and ED 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.

If your agency wants to target the current ACH and/ or ED measures, “I would look at the list of Potentially Preventable Hospitalization diagnoses,” Parson counsels. “Even though [the PPH measure] is not yet part of VBP, it will give agencies ideas on what diagnoses may be actionable on the part of agencies,” she says. And it will “help with developing care pathways and better chronic disease management for some of these diagnoses,” she offers.

The list of PPH diagnoses is on pp. 17-33 (pp. 21-37 in the PDF file) of the “Specifications for the Home Health Within-Stay Potentially Preventable Hospitalization Measure for the Home Health Quality Reporting Program” report by measure contractor Abt Associates at www.cms.gov/files/document/ proposed-pph-measure-specifications-cy22-hh-qrp-nprm.pdf.

Any help is welcome for these measures which may prove tough to manage. “Finding some care planning ideas and pathways to decrease our hospitalization rates” is going to rank as one of agencies’ biggest challenges under VBP, Parson predicts.