Home Health & Hospice Week

Value-Based Purchasing:

VBP Picture Becomes Clearer As HHAs Progress Into First Performance Year

Plus: Don't forget to check your latest QAO report.

Keep your eyes peeled for more critical info about your home health agency in the imminent — and final — Pre-Implementation Performance Report for Home Health Value-Based Purchasing.

Recap: The Centers for Medicare & Medicaid Services issued the first PIPR back in November 2022, then another one in January. Now comes the final PIPR before their next iteration, the Interim Performance Report (IPR), takes over in July. PIPRs contain agency-specific and national cohort data on the 12 VBP quality measures — five OASIS-based measures, two claims-based measures, and five CAHPS-based measures.

The initial PIPR issued in November contained only six months of OASIS data and three months of claims and CAHPS data, CMS noted at the time (see HHHW by AAPC, Vol. XXXI, No. 42). But the next PIPR, which CMS expects to issue in the last week of April, will contain a full year of OASIS data. In contrast, a full year of claims and CAHPS data will be in the first IPR in July.

Reminder: Expanded VBP’s first performance year began Jan. 1, and CMS will use calendar year 2023 data to determine HHAs’ VBP payment adjustments in CY 2025, a CMS official pointed out in the agency’s Home Health Open Door Forum on April 19. The April PIPR will include preliminary achievement thresholds and benchmarks based on the most recent available data, she noted.

Watch out: The OASIS-E instruction to exclude certain hospice discharges from the Discharged to Community measure, which took effect Jan. 1, may confuse HHAs trying to gauge their VBP stats. In VBP Frequently Asked Questions updated at the end of March, CMS explains that discharge to a non-institutional/home hospice marked in M2420 excludes that quality episode from calculation for the measure, the CMS staffer highlighted (see details of that FAQ in HHHW by AAPC, Vol. XXXII, No. 13).

In the question-and-answer portion of the forum, an attendee asked whether that exclusion would be applied to an agency’s information from the prior year, presumably for comparison’s sake.

The exclusion applies only to quality periods ending Jan. 1 and later, the CMS speaker suggested.

Other home health topics addressed in the forum include:

  • OASIS Q&As. The latest set of OASIS Questions and Answers, which CMS released April 18, also addresses excluded quality episodes for patients discharged to hospice at home (see story, p. 107).
  • Quality data submission. HHAs can see whether their latest quality data submission stats are on course to land them with a payment penalty. CMS issued the most recent Quality Assessment Only (QAO) reports in agencies’ iQIES folders on March 23, a CMS official said in the forum.

Reminder: The QAO performance requirement for the home health annual performance update (APU) is 90 percent, CMS says on its website.

The latest QAO reports cover CY 2022 with OASIS data submitted by Jan. 31, 2023, the CMS speaker detailed. The next QAO report is scheduled for late June.

  • Care Compare. Watch for an update to your home health Care Compare data by the end of the month, the CMS staffer told attendees.
  • CAHPS. This month marks the beginning of the newest year for CAHPS data collection, a CMS speaker noted in the forum. The CAHPS data year runs from April through the end of March so there’s time to calculate agencies’ data for APU compliance impacts.

CAHPS data collected from this month through March 2024 will affect HHAs’ 2025 payment rates, she explained.

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