CMS has finalized the expansion of the recently ended nine-state demonstration of the Home Health Value-Based Purchasing (HHVBP) program to include all 50 states. CMS postponed the start date of the expanded nationwide HHVBP from CY 2022, which was originally proposed, to now be CY 2023 as the first performance year with CY 2025 being the first year with payment impact. The model was designed to support greater quality and efficiency of care among Medicare-certified Home Health Agencies (HHA) across the nation. The HHVBP Model supports the Department of Health and Human Services’ efforts to build a health care system that delivers better care, spends health care dollars more wisely, and results in healthier people and communities.
During the nine-state demonstration, the HHVBP was based on an individual state-specific basis. Interpreted means, agency scores were only compared to other agencies’ scores within their own state. The expanded demonstration will have CMS applying the HHVBP in two cohorts: a national cohort of all “large” HHAs and the “small” HHAs national cohort. The small cohort will include agencies that are small enough to NOT be required to submit HHCAHPs data. The numbers that have been released include over 7,000 agencies in the large cohort and just under 500 in the small cohort.
CMS has finalized that 5% will be the amount of payment at risk or subject to a bonus based on Total Performance Score of outcome calculations and the application of the Linear Exchange Function. The measures used to calculate the Total Performance Score (TPS), in the HHVBP demonstration, will be drawn from Claims, OASIS and HHCAHPs measures. OASIS measures will require 20 home health quality episodes for a score to be calculated. Claims data will require 20 home health stays and HHCAHPs will require that at least 40 completed surveys are returned by beneficiaries in the period being calculated. Without these levels of data, outcome calculations will not take place for that category of measures. The TPS will be made up of OASIS measures – 35% of the score, Claims measures – 35% of the score and HHCAHPs – 30% of the score. For the small cohort there will be NO HHCAHPs scores and therefore the calculation will be split evenly between OASIS and Claims, 50% for each.
The expanded Model will use benchmarks, achievement thresholds, and improvement thresholds, based on baseline year data, to calculate achievement and improvement of HHA performance on quality measures. There will be an achievement score and an improvement score calculated for each of the outcome measures and the agency will receive the higher of the two calculated scores. Achievement scores can range from 0 to 10 points, while improvement scores can range from 0 to 9 points. If the outcome scores in the performance year are not at least as good as the scores from the baseline year the agency can receive 0 points in the calculations.
Following are the outcome measures listed by category:
- Improvement in Dyspnea/Dyspnea
- Discharged to Community
- Improvement in Management of Oral Medications/Oral Medications
- Total Normalized Composite Change in Self-Care/TNC Self-Care
- Total Normalized Composite Change in Mobility/TNC Mobility
- Acute Care Hospitalization During the First 60 Days of Home Health Use/ACH
- Emergency Department Use without Hospitalization During the First 60 Days of Home Health/ED Use
- Care of Patients/Professional Care
- Communications between Providers and Patients/Communication
- Specific Care Issues/Team Discussion
- Overall rating of home health care/Overall Rating
- Willingness to recommend the agency/Willing to Recommend
The 2022 Home Health Final Rule finalized the replacement of the Acute Care Hospitalization During the First 60 Days of Home Health (NQF #0171) measure and Emergency Department Use Without Hospitalization During the First 60 Days of Home Health (NQF #0173) measure with the Home Health Within Stay Potentially Preventable Hospitalization measure. This clarification includes that the two measures will be deleted from Home Health QRP, but these measures WILL continue to be calculated and reported in the Value-Based Purchasing demonstration.
Based on the 2022 Final Home Health Rule, CMS will use the agency’s Medicare Certification date to determine the HHA baseline year as follows:
- Medicare Certification prior to January 1, 2019: Baseline year = 2019
- Medicare Certification on or after January 1, 2019: Baseline year = the HHA’s first full calendar year of service beginning after the date of Medicare certification, except for HHAs certified on January 1, 2019 – December 31, 2019 – agencies certified in 2019 will have 2021 as their baseline year. Calendar year 2020 will NOT be utilized for any data in HHVBP.
In the PROPOSED Rule for 2023, it is being proposed that the baseline year be moved to 2022 for all, instead of having 2019 as the Model Baseline Year and multiple years used for the agency baseline, based on the year of Medicare Certification.
In early May 2022, CMS released the benchmarks and achievement thresholds for both cohorts, based on 2019 being the baseline year. Software vendors that are providing agencies will analysis as to where the agency stands as compared to the nation, can expect that these vendors will be working hard on those updated scores. If the 2023 Proposed Rule is finalized as it is written these numbers will change to 2022 numbers.
Regarding what agencies need to do now in preparation for HHVBP to be rolled out nationwide:
- Review your standings as of the end of the HHVBP Demonstration if you were in the nine-state demonstration. Understanding that you will now be compared to all agencies in the nation and not just your state.
- Review all current outcome measure scores that are applicable to HHVBP and focus education on any with deficits.
- Ensure that you are reviewing the HHCAHPs volume of responses as well as the outcomes of the returned ones. There might be needed consideration of changing vendors.
- Focus attention on the avoidance of Emergency Department use and Rehospitalization of your patients.
Healthcare Provider Solutions is standing by to assist you, in any way needed, as we approach implementation of the HHVBP demonstration in January 2023. If you need help navigating the expanded Home Health Value-Based Purchasing Model, contact us today!