The Centers for Medicare and Medicaid Service (CMS) released the CY2019 Medicare Home Health payment rule July 12, 2018. You can view the proposed rule here. The 2019 proposed changes to home health prospective payment rates are the typical changes that have been occurring for the last few years.
A large and important part of this Proposed Payment Rule are the proposed changes to the Value-Based Purchasing (VBP) Model.
One of the agency’s proposed refinements of VBP is removing five measures while adding two new proposed composite measures. OASIS based process measures “Influence Immunization Received for Current Flu Season” and “Pneumococcal Polysaccharide Vaccine Ever Received” would be removed completely, while “Improvement in Bathing,” “Improvement in Bed Transferring” and “Improvement in Ambulation-Locomotion” would be replaced by two normalized composite measures that use the aforementioned measures in the composite calculations:
- Total Normalized Composite Change in Self-Care, which computes the magnitude of change based on a normalized amount of possible change for the following measures:
- Improvement in Grooming
- Improvement in Upper Body Dressing
- Improvement in Lower Body Dressing
- Improvement in Bathing
- Improvement in Toileting Hygiene
- Improvement in Eating
- Total Normalized Composite Change in Mobility, which computes the magnitude of changes based on a normalized amount of possible change for the following measures:
- Improvement in Toilet Transferring
- Improvement in Bed Transferring
- Improvement in Ambulation/Locomotion
In addition to removing and adding measures, the proposed payment rule also calls for a reduction to the amount of improvement points an agency can earn in the value-based purchasing model, another factor taken into account for payment adjustments. CMS has made it clear that the agencies that started VBP with really low scores have, basically, had time to catch up, so this proposed rule includes a plan for there to be “a slightly stronger focus on achievement.”
CMS is proposing to recalibrate the weighting for measures that are OASIS based, claims based and HHCAHPS based. For the first three years of VBP, the measures were weighted the same for the purposes of payment adjustment. For 2019 CMS is proposing to use the following weights for the four measure categories:
- OASIS Based measures: 35%
- Claims-based measures: 35%
- HHCAHPS measures: 30%
If an agency is not scored in an entire measure category, the remaining categories would be increased proportionally. CMS notes that OASIS based measures have been steadily improving, while claims-based measures have been flat. CMS is expecting that by increasing the weight of claims based measures agencies will be encouraged to focus on improvement in those areas.
This proposed rule is voluminous and carries an immense number of proposed changes. HPS conducted a webinar on August 16, 2018, specific to the 2019 Home Health Proposed Rule. This webinar was recorded and the recording has been uploaded to the HPS Alliance dashboard. This webinar should assist in developing comments on this proposed rule that are due August 31, 2018, by 5:00 pm Eastern Standard Time.