Home Health & Hospice Week

Public reporting, population base blasted.

Commenters on the 2017 Home Health Prospective Payment System rule continue to express confusion and indignation over the size of the risk pool for Value-Based Purchasing.

Reminder: VBP will start with 5 percent of home health agencies’ payments at stake in 2018 (based on this year’s data) in the nine VBP states, and will top out at 8 percent five years later.

“Advocate at Home has serious concerns that the HHVBP requires HHAs participating in the VBP demonstration to face potentially significant downside risk in the first payment adjustment year,” said the Downers Grove, Ill.-based agency in its comment letter. “No other VBP programs expect acute or post-acute providers to assume a potential downside risk to payment adjustment of five to eight percent, particularly so early on in the development of the VBP demonstration.”

HHAs and provider reps recommended a reduced risk pool anywhere from 1 percent to 4 percent instead.

Other VBP topics frequently raised in comment letters include:

• Thumbs up: Provisions that received widespread praise included changing flu vaccination reporting to an annual basis; trimming the VBP “starter set” by four items to total 20; and lengthening the data reporting period for New Measures from seven to 15 days.
• Public reporting: Many commenters expressed reservations about public reporting of VBP data. “A serious flaw in current public reporting is that different methodologies are used for the Quality of Patient Care star ratings vs. the HHCAHPS (patient experience) star ratings, which creates confusion for consumers,” noted chain Amedisys Inc. in its comment letter. “In addition, it is difficult for consumers to understand the lag time between the performance period and the report that they are reading. We recommend a total redesign of current public reporting websites before adding VBP data.”

“Public reporting is premature in this initiative, as this is a demonstration pilot,” said one commenter from Missouri. “Public reporting should only occur once CMS has had the opportunity to evaluate this pilot and determine its effectiveness in achieving the goals, particularly as compared to the improvement in states who are not competing in the pilot.”

• VBP population. Numerous commenters criticized CMS’s change to VBP calculations that would include Medicaid and managed care patients.  “Other payers often place constraints on the care that is being provided to patients, such as the limitation of visits,” pointed out the Association for Home Care & Hospice of North Carolina and South Carolina in its comment letter. “Quality measures across these payers are not comparable.”

“Medicaid home health services do not have a ‘homebound,’ ‘skilled care,’ or place of residence requirement for benefit eligibility,” noted the National Association for Home Care & Hospice.

“This results in an entirely different patient population than traditional Medicare with different influences on patient outcomes. It is not logical to compare HHAs who serve Medicaid patients at a school or place of work with HHAs that confine their patient population to traditional Medicare enrollees.”

The same goes for managed care. “These patients are subject to care authorizations by the MA plan, not the patient’s physician as in traditional Medicare,” NAHC continued. “These patients are also case managed throughout the care continuum where home health is used in significantly different ways that traditional Medicare home health services. There is no MA enrollee risk adjuster in place that accounts for these differences.”