Home Health & Hospice Week

Plus: Is there any possibility of 2024 rate reduction relief?

If you want to survive and thrive under the new Value-Based Purchasing payment model that started its first performance year Jan. 1, you’d better be paying close attention to that performance. Many home health agencies may not be doing that, indicated a Medicare official in the Aug. 30 Home Health Open Door Forum.

Reminder: The Centers for Medicare & Medicaid Services published HHAs’ first interim preview reports on July 21 (see HHHW by AAPC, Vol. XXXII, No. 27). IPRs are crucial because they help agencies evaluate their performance in reference to others in their cohort, when that performance could affect their payment rates up to 5 percent positively or negatively.

Many HHAs have not yet accessed their July reports, a CMS official signaled in the forum. “We encourage anyone who did not access the July data to do so and to access each upcoming quarterly report,” CMS’ Marcie O’Reilly urged attendees. “The next IPR will be available in October,” O’Reilly added.

Providers and their representatives may also want to take part in a new VBP Technical Expert Panel CMS is convening in November. TEP members “will be discussing potential future quality measures to be added to the applicable measure set, reevaluating the weighting of the measure categories, and the possible application of a health equity adjustment,” O’Reilly revealed.

CMS will issue a call for TEP nominations “in the next few days,” O’Reilly said.

Additionally, CMS plans to boost its educational efforts to help agencies succeed under the model, O’Reilly continued. “We will be hosting HHA perspectives. These panel discussions will include individual HHAs discussing their approaches to quality management and innovation,” she explained. “Please keep an eye out for more information on these.”

Other home health topics covered in the forum include:

• 2024 home health proposed rule. The comment period on the rule closed Aug. 29, CMS’ Jermama Keys noted in the forum. The final rule will be out “end of October-ish,” CMS’ Brian Slater reminded attendees.

In the question-and-answer portion of the call, Andrew Baird, Enhabit Home Health’s VP for government affairs, noted that “in last year’s rulemaking, CMS decided to … reduce the proposed permanent adjustment by half as a recognition of the potential hardship of implementing that full permanent adjustment in a single year.” Baird then asked CMS officials whether “given the impact that CMS has broadcast and some of the modeling folks have done about the proposal for this year … CMS believe[s] that it has the same authority in this year’s rulemaking to potentially take the same types of steps to mitigate the impact of this year’s proposed rule.”

Reminder: CMS has proposed cutting HHA rates 2.2 percent, based on a 5.1 percent behavioral adjustment.

Slater, who is the CMS Home Health & Hospice Division Director, noted that the agency is not allowed to comment on issues undergoing active rulemaking. However, “I appreciate your viewpoints, and I’m sure that we got your comments, and they’re going through them,” he assured. Watch for a final decision on that issue in final rule.

• Care Compare. Your quality stats on Care Compare will update in October, Keys reiterated. The preview reports for those expired Aug. 16.

“That October 2023 refresh will add a new claims-based measure for public reporting, the Potentially Preventable Hospitalizations or PPH,” Keys highlighted. The update also will remove an OASIS-based measure from public reporting — Drug Education on All Medications Provided to Patients/ Caregivers. CMS has indicated that process measure was topped out.

• QAO Retention. If you want to keep a record of your Quality Assessment Only stats over time, you need to be proactive, because CMS isn’t going to do it for you.

The QAO interim and annual performance reports will remain in iQIES folders for 120 days, Keys emphasized. “Once the retention period has been reached or the file is over 120 days, then the files are permanently deleted from the HHA’s user folders, and they will no longer be accessible,” she cautioned.