The Home Health Proposed Rule was posted by CMS on the Federal Register July 10th and it was full of surprises, especially in light of the much anticipated proposal on Value Based Purchasing (VBP). One major surprise was the episodic rate adjustment of -1.72% due to the infamous “case-mix creep” for both 2016 and 2017.
Odds were expected to be in the industry’s favor of no adjustments as agencies are now in the third of four years of rebasing cuts.
With the VBP proposal, it was somewhat of a surprise that CMS did not heed the concerns voiced by the industry regarding the magnitude of the proposed penalties/rewards. The proposed payment adjustments will start at 5% in the performance year 2016 and rise to 8% by the end of the 5 year pilot program that is being conducted in 9 randomly selected states (surprise if you are one of them).
Given that the new Quality of Patient Care Star Ratings are based on 9 measures and HHCAHPS on 5 measures, it was a surprise to see that the proposal for VBP combines 15 outcome and 10 process measures in addition to 4 new measures (another surprise):
- Adverse Event for Improper Medication
- Flu Vaccine of Health Care Personnel
- Shingles vaccination
- Advanced care plans
Note: Each of these new measures will need to be manually entered into a CMS web portal
Although not a surprise, the case mix weights are all being recalibrated again. Across the 153 HHRGs, the case weights are changing from a decrease of -3.35% to an increase of 3.62%. Over 75% of the HHRG changes are negative with an overall average decrease of 0.8%. Interestingly, one of the OASIS categories for scoring clinical dimension points that was dropped last year was added back for 2016. In addition, many of the points and thresholds have changed in the proposal for 2016.
To help agencies see where the changes were made, SHP has prepared a PPS and NRS Point Scoring Comparison Guide on how the HHRG scoring is affected, including the mapping and scoring of the new clinical and functional domains. The service domains are not changing at this point.
A couple of noted differences:
- Points are now available for Neuro 1 - Brain disorders and paralysis when M1840 = 2 or more
- 35 of the 41 Scoring categories have changes in the points given (both up and down)
- The number of points needed to go from a C1 to C2 clinical severity level decreased for episodes with 14-19 therapy visits
- NRS scoring had no changes
With every change that CMS makes, it is important home health agencies increase their efforts to ensure the OASIS coding processes are continually evaluated for accuracy and efficiency. Stay tuned for more information from SHP regarding VBP and how to make sure your organization is prepared.