Home Health & Hospice Week

You can expect your IPR baseline year data halfway through the first performance year — if you’re lucky.

Home health agencies that counted on benefitting from their quality improvements between 2019 and 2022 are out of luck in the 2023 home health final rule.

Why? Over strident protest, the Centers for Medicare & Medicaid Services has finalized its decision to move the Value-Based Purchasing baseline year forward three years to 2022. That goes for both the new HHA and Model baseline years, unless a provider doesn’t make the date cutoff for 2022.

CMS swats down provider criticisms of the change on a number of fronts, arguing that it didn’t violate any notice and rulemaking procedures as alleged;

For agencies concerned that the COVID-19 pandemic would skew data, “the healthcare system has since begun to return to normal and stabilize,” CMS insists. “CY 2022 is the first year where the vast majority of beneficiaries are vaccinated” and “there were viable treatments available and healthcare providers had nearly 2 years of experience managing COVID-19 patients,” the agency continues.

For HHAs that were planning to shoot for improvement points, “we recognize that changing the Model baseline year from CY 2019 to CY 2022 will affect individual HHAs differently based on their quality performance efforts over the last year,” CMS says. Such agencies should set their sights on achievement points instead, CMS suggests. “Quality improvement efforts undertaken by HHAs that show impact on performance year quality scores may be recognized through achievement points, regardless of when those efforts were initiated,” CMS encourages.

Despite numerous agencies urging CMS to postpone expanded VBP if it moves the baseline year, the agency maintains that it “does not believe that it is necessary to postpone the first performance year” and will get agencies their VBP data “as soon as administratively possible.” That includes “before the start of the CY 2023 performance year and again periodically before the first IPR [Interim Performance Report] scheduled for July 2023,” according to the rule.

“We believe that more recent data from the CY 2022 time period is more likely to be aligned with performance years’ data under the expanded Model, and provide a more appropriate baseline for assessing HHA improvement for all measures under the Model as compared to both the pre-PHE CY 2019 data, as previously finalized for existing HHAs, and the CY 2021 data, as previously,” CMS concludes.

Note: Expanded HH VBP info is at https://innovation.cms.gov/innovation-models/expanded-home-health-value-based-purchasing-model.