Home Health & Hospice Week

Value-Based Purchasing:

Medicare Clears Up A Question About VBP’s Smaller Cohort

Value-based care delivery is here to stay, expert predicts.

Home health agencies’ payment levels in 2025 depend on their quality scores right now, but many details of the Expanded Home Health Value-Based Purchasing program are just coming info focus.

For example, in its Feb. 28 update to the VBP Frequently Asked Question set, the Centers for Medicare & Medicaid Services addresses one program aspect for the smaller cohort.

Reminder: VBP has two nationwide cohorts for competition — small (fewer than 60 unique survey-eligible beneficiaries in the calendar year prior to the performance year) and large (60 or more unique survey-eligible beneficiaries). In 2019, 7,084 HHAs fell within the larger-volume cohort and 485 HHAs fell within the smaller-volume cohort, CMS calculated in its 2022 rulemaking cycle.

Question: “Are HHCAHPS Survey-based measures included in Total Performance Score (TPS) calculations for the smaller-volume cohort?” asks new FAQ Q3019.

Answer: “Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) Survey-based measures are not included in the TPS calculations for the smaller-volume cohort. These measures are not calculated in expanded HHVBP Model performance reports for the smaller-volume cohort and no achievement thresholds or benchmarks are calculated,” CMS responds.

“The expanded Model national cohorts were constructed to group HHAs of similar size that are likely to receive scores on the same set of measures for the purposes of setting benchmarks and achievement thresholds and determining payment adjustments,” CMS further explains. “While some HHAs in the smaller-volume cohort have sufficient data to calculate HHCAHPS Survey-based measures, these HHAs constitute a small subset of the cohort.”

Bottom line: “HHCAHPS survey-based measures are not reported or included in TPS calculations for the smaller-volume cohort so that HHAs in this cohort are more likely to receive scores on the same set of measures,” CMS concludes.

Remember, your agency’s Pre-Implementation Per­formance Report (PIPR) in iQIES — the program’s second, issued in January — includes your agency’s preliminary cohort assignment. The PIPR also contains your value by VBP measure and that value’s ranking within the cohort, and four cohort data points for each measure — the 25th percentile, 50th percentile, 75th percentile, and mean of 90th percentile.

It’s imperative to know the ropes of the VBP program, experts stress.

“CMS continues to remind us that it expects all Part A and B Medicare beneficiaries to be in a care relationship with accountability for quality and total cost of care by 2030,” notes attorney Christine Burke Worthen with law firm Nelson Mullins Riley & Scarborough. For expanded HH VBP, “2023 is the first performance year, and the results will impact 2025 payments,” Burke Worthen reminds agencies in online legal analysis.

Watch out: “It is important to note that commercial payers are also looking to change their reimbursement mechanisms to align with the CMS initiative,” Burke Worthen emphasizes.

“Value-based care delivery continues to impact a greater piece of the care delivery continuum and shows no signs of slowing down,” Burke Worthen observes. HHAs “can position themselves for success by being familiar with CMS program models and requirements and by ensuring commercial contract negotiations are optimized for sustainable reimbursement over the long term,” she advises.

Note: More VBP details are at https://innovation.cms. gov/innovation-models/expanded-home-health-value-based-purchasing-model. The 63-page FAQ set is at https://innovation. cms.gov/media/document/hhvbp-exp-faqs.

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