The first performance period for the Home Health Value-Based Purchasing (HHVBP) started on January 1, 2016, and just in the nick of time, CMS posted the long awaited answers to some of the open questions asked during the November 4th Open Door Forum (read more about it in our November blog post). On December 31st, CMS released their first Q&A on the CMS website.
One of the key questions that was answered relates to the OASIS measures. CMS has confirmed that they will be calculated using OASIS assessments from Medicare FFS, Medicare Advantage, Medicaid FFS, and Medicaid Managed care. Although language in the final rule implied Medicare FFS only, this clarification is consistent in how Home Health Compare (HHC) benchmarks are currently posted.
What is still unknown is how the 5 OASIS-based measures that are not currently part of HHC will be calculated. These measures are shown below:
|Discharge to Community||Outcome||OASIS (M2420)|
|Care Management: Types and Sources of Assistance||Process||OASIS (M2102)|
|Prior Functioning ADL/IADL||Outcome||OASIS (M1900)|
|Influenza Vaccine Data Collection||Process||OASIS (M1041)|
|Reason Pneumococcal Vaccine not received||Process||OASIS (M1056)|
Although the basic calculations for a couple of these measures may be obvious, the exact numerators and denominators were not well defined in the Final Rule. CMS indicated that more information regarding these measures will be presented during a webinar tentatively scheduled for January 2016.
Another helpful response was in regards to the New Measures. In the question whether data be entered in aggregate or per patient, “data is to be entered as it is currently submitted to OASIS, which is patient level data”. At least agencies have time to prepare. The data collection for the New Measures doesn’t start until Q3 of this year, with data submitted by October 7, 2016. CMS also noted that data elements required for reporting on New Measures will be provided to Model participants via a webinar, again tentatively scheduled for January 2016.
In regard to when benchmarks and thresholds will be available to competing HHAs, CMS noted the OASIS measures will be available in April 2016, and the HHCAHPS measures and claims measures will be available by July 2016. This is a little late for benchmarking your performance for outcomes that have already started this month. CMS does note that “because benchmarks and achievement thresholds of most measures are based on industry averages that do not vary significantly over a period of several years, we anticipate preliminary aggregate level benchmarks and achievement thresholds for the OASIS, HHCAHPS and Claims measures based on data for 2013 and 2014 will be made available sooner.”
HHVBP is very challenging and there is still more we need to know regarding this new model. Join Zeb Clayton and me on Wednesday, January 20th at 11:00am PST, for a HHVBP webinar where we will discuss the background and methodology of this new program based on the Home Health final rule for CY2016, and share some insights as to how providers should prepare for these changes. Register for “Home Health Value-Based Purchasing – Will You Be Ready?” here.