Medicare Compliance & Reimbursement
How HHAs Are Preparing For P4P
Pay-for-performance could determine home health agencies' Medicare payments soon, if policy- and lawmakers get their way.
The Centers for Medicare & Medicaid Services is readying a P4P demonstration for HHAs. Congress is requiring HHAs to report quality data starting in January. And the Medicare Payment Advisory Commission is recommending quality measures for P4P.
"P4P will be a force throughout the health care market," said Amanda Twiss, president of Seattle-based benchmarking company Outcome Concept Systems, in a recent P4P presentation at the National Association for Home Care & Hospice's annual policy conference in Washington, DC. Twiss offered attendees these six tips to succeed under P4P.
1. Educate yourself and staff. HHAs can't pretend P4P isn't happening when it's right around the corner. While neither CMS nor Congress have laid out P4P details yet, there are plenty of basics HHA management and staff should get to know, Twiss advises.
HHAs will likely start out with P4P based on the current home health quality improvement measures they already report, noted MedPAC analyst Sharon Bee Cheng in the same presentation. That's especially the case for the outcomes providers report on Medicare's Home Health Compare Web site.
As a strategy, some agencies already are tying staff payment levels to certain quality measures to prepare them for life under P4P, Twiss notes.
2. Gauge your P4P standing today. Now's the time for HHAs to assess how they're performing, so they can map out a plan to improve that performance if necessary.
"Look at how you stack up compared to other agencies," Twiss recommends to HHAs. To prepare for P4P, agencies should reference national rather than regional numbers, she adds. That's because CMS will likely base a nationwide P4P system on national statistics.
HHAs should take careful note of what types of patients they serve, Twiss counsels. With the shortcomings of the current risk adjustment system, different types of patients will affect their payments under P4P.
3. Implement disease management. The formula for success under P4P is very similar to the one for success with disease management programs, Twiss notes. Both focus on patients with chronic conditions, require patient compliance and process management. HHAs that can get a handle on successful DM are a long way toward succeeding with P4P. And starting with DM now is a way HHAs can be prepared when P4P finally hits, Twiss says.
4. Predict patients' outcomes. Under P4P, HHAs will have limited resources to get their patients' outcomes up to a certain level--or they'll lose money. Agencies should use the data they gather in a patient's assessment to predict potential outcome problems, and to direct resources to combat those potentially negative results, Twiss advises.
Most HHAs and their admitting clinicians already do this instinctively, using experience to predict when a patient is ripe for trouble such as a hospitalization or emergent care episode, Twiss acknowledges. Doing the same thing in "a more data-centered way" will help agencies and their patients steer clear of money-losing outcomes under P4P. Armed with the predictive data, "providers can use DM and tailor interventions to directly impact the outcomes of patients most at risk," she explains.
5. Make a P4P commitment. HHAs will only succeed at P4P if their organization--and especially their management--prioritize the issue, Twiss stresses. That includes setting out a defined improvement methodology, dedicating resources to the topic and training staff. Frontline staff won't focus on improving quality without support from their organization's overall commitment to quality, she says.
6. Be proactive. Home care is just starting its journey into P4P. That means HHAs have a window of opportunity to help shape the coming payment system and incentives, Twiss emphasizes. HHAs should be proactive in talking with CMS and other payers about how a P4P program should work, she urges.
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