Home Health & Hospice Week

Comment on proposed rule before you lose your chance.

Third time’s the charm for the first Value-Based Purchasing Interim Performance Report.

Why? The Centers for Medicare & Medicaid Services first issued the inaugural IPR under VBP on July 21, but then reissued corrected reports Aug. 1. Home health agencies had until Aug. 16 to submit any recalculation requests.

Now the final IPRs are “available on iQIES, in the ‘HHA Provider Preview Reports’ folder, by the CMS Certification Number (CCN) assigned to the HHA,” CMS says in a new email to providers. “The Final IPR reflects any changes resulting from an approved recalculation request,” the agency explains. “All HHAs that received a Preliminary IPR will receive a Final IPR, even if the HHA did not submit a recalculation request,” it adds.

As a reminder, the reports include an HHA’s interim measure performance scores and an interim Total Performance Score (TPS); improvement, achievement, and care points reflecting the HHA’s performance relative to its own performance and the performance of other HHAs in its cohort, including the achievement thresholds and benchmarks for the HHA’s cohort; measure scorecard information to support HHAs understanding how each individual measure contributes to their interim TPS; and a Total Normalized Composite (TNC) Change Reference tab to assist HHAs in understanding their performance on the individual OASIS items included in the two TNC measures.

In short, the reports give agencies an idea of how they are competing under VBP and where they need to improve. Payment adjustment information, however, won’t come until CMS issues agencies’ Annual Performance Reports (APRs), published annually beginning in August 2024.

And agencies can keep their data to themselves for the time being. “IPRs are not available to the public,” CMS stresses.

Resource: If you need help understanding your final report, you can now view a recording of CMS’ July 27 webinar, Overview of the Interim Performance Report (IPR): The July 2023 IPR. The one-hour webinar is at www.youtube. com/watch?v=p_qkXnjffIc.

Comments On Proposed Rule VBP Provisions Are Due Aug. 29

Do this: And don’t forget to comment about VBP changes included in the home health 2024 proposed rule. CMS wants to reshuffle and reweight quality measures for the program, as well as move the model baseline year to 2023 for the performance year starting 2025. That’s just a year after CMS moved the baseline year from 2019 to 2022, despite industry criticism of the change.

“The proposed changes to HHVBP, especially the proposal to move the baseline year, present additional challenges,” warn attorneys Robert Markette Jr., Lauren Hulls, and Erin Deckard with law firm Hall Render in Indianapolis. “Shifting the baseline year may impact future performance under HHVBP,” the attorneys warn in online rule analysis.

Comments are due by Aug. 29. Submit electronic comments at www.regulations.gov/docket/CMS-2023-0113/ document.