Home Health & Hospice Week

Under newly proposed configuration, half of VBP points will come from only 2 measures.

As home health agencies navigate through their first year of the Expanded Home Health Value-Based Purchasing program, Medicare is proposing to change the rules of the game.

The Centers for Medicare & Medicaid Services wants to swap out the quality measures used to generate HHAs’ VBP scores and reweight them, which could mean things you’ve targeted for quality improvement could become moot.

In its 2024 home health proposed rule, CMS proposes to make these changes effective Jan. 1, 2025:

• Replace the two Total Normalized Composite Measures (for Self-Care and Mobility) with the Discharge Function Score (DC Function) measure;
• Replace the OASIS-based Discharge to Community (DTC) measure with the claims-based Discharge to Community- Post Acute Care (DTC-PAC) Measure for HHAs; and
• Replace the claims-based Acute Care Hospitalization During the First 60 Days of Home Health Use and the Emergency Department Use without Hospitalization During the First 60 Days of Home Health measures with the claims-based the Potentially Preventable Hospitalization (PPH) measure.

In other words, CMS wants to remove five measures and replace them with three measures, and then reweight them, the rule summarizes (see chart, p. 191, for reweighting).

Why make these big changes just as HHAs are getting going? “The proposed changes will align the measures used in the expanded HHVBP Model with the measures in the HH QRP and publicly reported on Home Health Care Compare. This alignment will support comparisons of provider quality and streamline home health providers’ data capture and reporting processes,” CMS says in the rule.

The claims-based DTC-PAC measure also “assesses broader outcomes by assessing post-discharge hospitalization and mortality. Specifically, it first examines whether a patient was discharged to the community from the PAC setting. For patients discharged to the community, this measure examines whether they remained alive in the community without an unplanned admission to an acute care hospital or LTCH in the 31-day post-discharge observation window following discharge to the community,” CMS praises.

But CMS’ claim of QRP alignment doesn’t hold for the DC Function measure, which is only proposed for QRP inclusion starting in 2025 (see related story, p. 192). CMS has a preemptive response for that. “While the DC Function measure is not yet implemented in the HH QRP or other PAC programs, the OASIS data elements used to calculate this measure have been collected since 2019. As such, we believe HHAs have had sufficient time to ensure successful reporting of the data elements needed for this measure,” the rule argues.

CMS also praises the DC Function measure because it “addresses self-care and mobility through a single measure rather than two measures, thereby streamlining the calculation and reporting of measure results.”

On the other hand, the PPH measure has been in the works for a while and is scheduled to go live on Home Health Care Compare later this month (see HHHW by AAPC, Vol. XXXII, No. 13). “Replacing ACH and ED Use with PPH would further align the expanded Model’s applicable measure set with the HH QRP measures,” CMS notes in the rule.

The five CAHPS-based measures will remain the same under VBP. CMS also wants to reweight the measures once they are in place (see chart, p. 191).

And the agency suggests rebasing the model year yet one more time, moving it to 2023 for the performance year starting 2025.

Background: CMS originally set the baseline year at 2019, then last year moved it to 2022 over much industry protest via rule comment letters and other avenues.

“If we finalize our proposal to use CY 2023 for the Model baseline year, we would provide HHAs with the final achievement thresholds and benchmarks in the July 2024 Interim Performance Report (IPR),” CMS offers. “For all measures but the claims-based DTC-PAC measure, this timeline allows for one year of performance between the first performance year and the proposed updated Model baseline year.” The DTC-PAC measure is an exception because it is based on two years’ of data.

CMS considered delaying implementation of the new measures in a variety of configurations, the rule discussion reveals. But “we prefer the proposed timeline … because it expedites alignment with the HH QRP, SNF VBP, and the other PAC programs and the timing corresponds with the proposed removal and replacement of other measures in the Model,” it says.