Home Health & Hospice Week

This time next year you should be putting finishing touches on your VBP implementation plans.

In its 2022 home health final rule, the Centers for Medicare & Medicaid Services says it will bump VBP’s start date by one year to January 2023. “The first performance year of the expanded HHVBP Model will be CY 2023, with quality performance data from that year used to calculate payment adjustments under the expanded Model in CY 2025,” CMS says in a fact sheet about the rule published in the Nov. 9 Federal Register.

In its rule materials, CMS focuses more on the implementation of VBP and less on the delay of its implementation date. VBP “furthers CMS’ strategic commitment to drive innovation that promotes comprehensive, person-centered care for older adults and people with disabilities by accelerating the shift from paying for home health services based on volume, to a system that incentivizes value and quality,” the agency says in a release.

“CMS is committed to helping people get the care they need, where they need it,” CMS Administrator Chiquita Brooks-LaSure says in the release. “This final rule will improve the delivery of home health services for people with Medicare.”

Recent CMS analysis shows “an average 4.6 percent improvement in HHAs’ quality scores and an average annual savings of $141 million to Medicare” in the first three years of the HHVBP’s model, which ran in nine states, the agency notes. “These policies support the Agency’s commitment to advancing value-based care by providing incentives for HHAs to improve the beneficiary experience and quality of care.”

In the rule, CMS notes that “the majority of commenters supported a home health value-based purchasing payment model, but were opposed to expansion beginning in CY 2022 as the first performance year.” Reasons to oppose rushed implementation ranged from the impact of the COVID-19 Public Health Emergency to requiring more time for operationalization of the model.

“We are finalizing a one-year delay in assessing HHA performance and the calculation of a payment adjustment,” CMS says in the final rule. “After consideration of the comments received, we are … finalizing that CY 2022 will be a pre-implementation year,” CMS explains.

What exactly is a “pre-implementation year,” agencies may ask. “We will provide learning support about the Model to HHAs during CY 2022,” CMS says. “By delaying payment adjustments by one year and providing HHAs with learning support in the pre-implementation phase, all HHAs will be better prepared to participate in the Model for the CY 2023 performance year. HHAs will incur a 0 percent payment adjustment risk for the CY 2022 pre-implementation year,” the agency adds in the final rule.

“Throughout 2022, we will provide learning support about the expanded model to all HHAs,” confirmed a CMS official in the Nov. 10 Home Health Open Door Forum.

The pre-implementation year should give HHAs in non-VBP states the chance to catch up to those in the nine states that have already operated under (they believed) five years of the model.

HHAs and their representatives are happy to hear about the delay. “The biggest news in this final rule is that the Value-Based Purchasing Model Nationwide Rollout will not go into effect until January 1, 2023,” cheers Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tennessee. “With this nationwide rollout being put off until January 2023, CMS is allowing for agencies to receive additional education to be able to figure out exactly how this Value Based Purchasing process works and be able to more fully understand how your agency can be successful under the … Model,” Gaboury says in her Monday Minute with Melinda vlog.

“CMS is giving agencies time to prepare before … HHVBP begins impacting payments,” consulting and solutions company Corridor in Overland Park, Kansas, stresses on its website.

“It is definitely good news that VBP has been delayed for a year,” Gaboury tells AAPC. That’s especially true “for agencies that don’t realize what this could mean” and have yet to start VBP prep in earnest.