Home Health & Hospice Week

Stay tuned for further details revealed in CMS’ Nov. 17 livestream.>

Although your home health agency may be deluged with duties, you need to focus on wringing every bit of usefulness out of an important new Value-Based Purchasing tool — the Pre-Implementation Performance Report (PIPR).

Recap: On Nov. 8, the Centers for Medicare & Medicaid Services unveiled the new PIPR, which it made immediately available for download in HHAs in iQIES. The report gives agencies preliminary data on 12 VBP measures including two composite measures on mobility and self-care (see HHHW by AAPC, Vol. XXXI, No. 41).

“Agencies might be feeling a bit overwhelmed right now,” acknowledges consultant Linda Scott of Scott Solutions in Arlington, Virginia. “Balancing clinical resource time for patient care and staff training and development around OASIS-E/VBP are very tricky, at times, and we have a big holiday season pending, and patient care always comes first,” Scott observes.

There’s “no need for a fire drill,” Scott tells AAPC. “Just get started if you have not,” she advises.

And no matter how far along in the VBP-focused quality improvement process you are, the PIPR will contain brand new data you haven’t seen before that is essential to review ASAP, experts agree.

The reports are chock full of new info, including possibly the most crucial — a first look at your cohort comparison data.

“These reports will allow agencies to see how they compare against their cohort using data from CMS,” stresses consulting director Charles Breznicky Jr. with SimiTree. For the first time, “these reports will allow agencies to view the data that will be used by CMS, which is especially important when trying to compare against national averages,” Breznicky explains.

“Getting agency-specific data is welcome for providers, especially so soon after the final rule finalized the HHA baseline year ... as 2022 as opposed to 2019,” notes managing consultant Angela Huff with FORVIS in Springfield, Missouri.

And CMS will issue two more quarterly PIPRs, in January and April, before transitioning to the Interim Performance Reports in July 2023. That will allow agencies “a sense of how they may be improving over time,” Breznicky notes.

“Having this initial preview data will help providers prepare and finalize plans to achieve success with VBP kicking off in just a few short weeks now,” Huff tells AAPC. “This may be the first time organizations have insight into how they are performing in their cohort so they can refine their VBP management approaches if needed before the kick-off Jan. 1.”

Taking in and analyzing PIPR data should also help agencies to use similar IPRs right off the bat starting next summer, CMS suggests in its on-demand webinar about the PIPR.

Bottom line: The PIPR is “useful,” as it “allows agencies to see themselves, and their starting point now,” Scott notes. “Factual quantitative indisputable data — you collected it, you transmitted it, it is yours,” she cheers. “Here is what it looks like against the new measures of success for our industry.”

Plus, the PIPR “somewhat levels the playing field, so those agencies that don’t have or can’t afford third-party data analytics software can see where they stand,” Breznicky points out.

PIPR Drawbacks Include Data Lag

While the PIPR is a useful tool, it does have problems, experts agree.

For example: The timelines for different measures vary, Breznicky points out. “Agencies need to pay special attention to know which time frames are included in each report” and avoid confusion, he counsels.

“Also, the full 2022 data will not be available until April 2023 and that will only be for the OASIS-based measures,” Breznicky adds.

Review: “All three PIPRs will include at least some CY 2021 performance data,” CMS says in its webinar. “It’s important to note that performance data from CY 2021 will not be used in the calculations for the first payment adjustment year, CY 2025, under the expanded HHVBP Model,” it instructs.

“Providers only have six months of OASIS data and three months of the claims and CAHPS data” in this initial PIPR, Huff allows. But “it is certainly better than nothing and will be helpful to give visibility to where their organization stands based on their cohort,” she judges.