Home Health & Hospice Week

No immediate program shifts are a relief to HHAs.

Unlike last year, Medicare isn’t proposing any major Expanded Home Health Value-Based Purchasing Model changes in its annual home health proposed rule. But the regulation doesn’t neglect VBP altogether.

In the rule released June 26, the Centers for Medicare & Medicaid Services issues a Request for Information (RFI) on future performance measure concepts for the program. “As we continue to leverage our value-based purchasing initiatives to improve the quality of care furnished across healthcare settings, we are interested in considering new performance measures for inclusion in the expanded HHVBP Model,” CMS says in the rule.

The move “would build on input from the [HHVBP] Model’s Implementation and Monitoring technical expert panel (TEP), which met in November 2023,” CMS notes in its rule fact sheet. The panel discussed future measures such as “function measures complementing the existing cross-setting Discharge (DC) Function measure,” the agency reports. “These measures would include care activities like bathing and dressing, which are important for home health patients and caregivers but are not included in the DC Function measures.”

TEP members pointed out that the new DC Function measure “does not include the full selfcare/activities of daily living elements (for example, bathing, dressing), which they noted as critically important for home health patients and caregivers,” CMS acknowledges in the rule. And “patients often already have capacity to do things like roll and sit up when they enter home health care but may not be able to bathe or get dressed without assistance,” the rule recognizes.

Another potential addition could include “adding the existing Medicare Spending per Beneficiary measure in future rulemaking,” CMS says. “This cross-setting measure is part of the Home Health Quality Reporting Program and is currently publicly reported on Care Compare,” the agency reminds. “MSPB may be a valid tool for measuring the value of the care that HHAs provide that may be appropriate for use in the expanded HHVBP Model. The measure would provide information on the efficiency of home health providers, as measured by Medicare payments for their patients.”

CMS may also consider adding measures addressing “family caregiver status and claims-based falls with major injuries,” it adds.

For the caregiver measures, “CMS intends to develop a patient-reported outcome performance measure (PRO-PM) to assess caregiver burden in the Guiding an Improved Dementia Experience (GUIDE) Model that may be a useful example for caregiver measures that may be developed for HHVBP,” it offers. “Creating one or more measures based on an HHA’s ability to meet caregiver needs would permit measurement of changes in caregiver quality-of-life,” the rule highlights.

On the falls front, “while it may not be possible to identify all falls from claims data, a claims-based measure may be more accurate,” CMS muses in the rule. However, “as with other claims-based measures, data would only be available for Fee for Service patients.”

A CMS observation may spell the potential measure’s downfall, however. “Due to the high rate of non-reporting, the OASIS-based falls measure may not provide accurate information about the incidence of these falls,” the rule says.

CMS welcomes “general comments on other future model concepts” for VBP as well, it adds.

The rule also includes a somewhat lengthy update on a previous VBP RFI regarding health equity.

Note: Submit comments electronically at www.regulations.gov/document/CMS-2024-0190-0001.