Home Health & Hospice Week

Get friendly with PPH and other new measures.

Do you think you have the hang of value-based purchasing? You may have to think again, in light of payment model changes included in the 2024 home health final payment rule issued Nov. 1. If the Centers for Medicare & Medicaid Services floated a VBP change in the proposal rule, it pretty much adopted that change as proposed in the final rule, regardless of industry feedback.

For example: Most commenters on the proposed rule that addressed VBP made it clear that they opposed changing the baseline year to 2023 as proposed for performance year 2025 (see HHHW by AAPC, Vol. XXXII, No. 34). But CMS turns a deaf ear to that common criticism.

“We believe that it is beneficial to align the Model baseline year for the existing measures with the new measures, particularly given that the new measures contribute heavily to the HHA performance scores,” CMS says in the final rule. “Maintaining different Model baseline years could cause more burden and confusion, compared to updating the Model baseline year for all measures at the same time,” according to the rule scheduled for publication in the Nov. 13 Federal Register.

“CMS is moving the goal posts in the middle of the game,” protests attorney Robert Markette Jr. with Hall Render in Indianapolis. The change “may lead to reduced improvement and performance scores for the good providers and lead to unintended consequences,” Markette warns.

In response to criticism that moving the baseline year will reward providers who haven’t done much quality improvement work yet, HHAs can gain VBP points from achievement as well as improvement, CMS responds. “An HHA that has improved their overall quality will potentially get more achievement points attributed to their [Total Performance Score] than from improvement points and would potentially result in the same payment adjustment if we had not changed the baseline,” the agency offers.

CMS acknowledges that “final achievement thresholds and benchmarks will be provided in the July 2024 Interim Performance Report (IPR),” which commenters decried as too late.

But CMS assures that “to help provide feedback to HHAs on the applicable measure set effective in CY 2025, we plan to make the most current HHA-specific performance data for the applicable measures available to each HHA in iQIES. We intend for this to include current performance relative to other HHAs nationally as soon as administratively possible and before the start of the CY 2025 performance year and again before the first IPR scheduled for July 2025,” the rule pledges.

Another example: CMS is also moving ahead with removing five measures and replacing them with three measures, and then reweighting them (see chart).

The agency acknowledges that the “weight for the DC Function measure … is slightly higher than the current combined weight of the TNC measures” in its new VBP calculation. Some commenters were critical of the new measure (see related story, p. 308) and its weight in VBP.

“We selected this weight because of our belief that function is critical for beneficiaries to safely remain in their home,” CMS says. It’s “an important quality measure that should have the weight that it has in the expanded Model,” the rule concludes.

CMS rebuffs other suggestions for reweighting both new and old measures, but noted that it “will be convening a TEP and will solicit their input on weighting.”

Thus, CMS finalizes its proposals 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.

“All changes to the measure set begins with the CY 2025 performance year, thus all changes will affect the payment year beginning with the CY 2027 payment year,” the National Association for Home Care & Hospice explains in its rule summary.