CMS Home Health Final Rule delays HHVBP National Expansion

By Chris Attaya
November 18, 2021 Home Health

In the Medicare and Medicaid CY 2022 Home Health Prospective Payment System Rate Final Rule, CMS finalized the Home Health Value-Based Program (HHVBP) national expansion based on their original proposal. However, there is one exception - a one year delay in implementing the program. This is good news for providers in the 41 states which are currently not part of the CMMI HHVBP demonstration. Where the proposal aimed to expand the model nationally as of January 1, 2022, the extra year will provide more time for these agencies to learn more about the model design and start initiatives to improve outcomes in advance of the January 2023 roll-out.

the extra year will provide more time for agencies to learn more about the model design and start initiatives to improve outcomes in advance of the January 2023 roll-out.

It is interesting to note that CMS has labeled CY 2022 as a “pre-implementation year”. What jumped out to me was the following CMS comment:  “HHAs will incur a 0 percent payment adjustment risk for the CY 2022 pre-implementation year.” CMS later notes that they anticipate providing sample reports in CY 2022 similar to the Interim Payment Reports (IPR) as finalized for the CY 2023 performance year. This leads me to believe that CMS intends to administer the framework of HHVBP by providing both quarterly and annual reporting during the CY 2022 pre-implementation year to help prepare agencies, but without any adjustments. 

During the Nov 11th Open Door Forum, CMS did confirm they will be providing data regarding the 2019 achievement thresholds and benchmarks during the summer of 2022. That follows the timeframe to when the first IPR was originally proposed to begin. Again, this would provide helpful insights on how your agency is performing under the model.

In the proposed rule, CMS sought input regarding how to address the two HHVBP claims-based measures that will be removed from the Home Health Quality Reporting Program (HHQRP) in CY 2023. CMS plans to replace both the 60-day Acute Care Hospitalization and ED Use without Hospitalization with a single measure, Potentially Preventable Hospitalization (PPH), which CMS finalized in this rule.

Industry comments included better aligning the HHVBP measures to HHQRP, Star Ratings and other quality reporting activities to support better consistency in tracking outcomes and an easier way for beneficiaries and payers to assess quality. Another suggestion was to wait at least one year after PHH is reported to include as a HHVBP measure. CMS did not make any measure changes, but will evaluate options during future rule-making.

As you consider which HHVBP measures your agency should target for improvement, make sure you consider the Total Performance Score (TPS) measure weighting assigned to each applicable measure. Also consider the achievement range between the 2019 achievement thresholds and benchmarks. The tighter the range, the greater impact one or two percentage points can have on the TPS. 

For example, Dyspnea has a weighting of 5.83%, 60-day Acute Care Hospitalizations at 26.25% and Care of Patients at 6.00%. HHAs earn up to ten achievement points for each measure before the weighting is applied. Notice the changes in the weighted points generated from improving quality scores using the SHP’s estimated 2019 national achievement thresholds and benchmarks on the table below.

Quality Measure Achievement Threshold (median) Benchmark (mean of top decile) Range (Threshold - Benchmark) 25% Score Improvement 50% Score Improvement 75% Score Improvement 2% Point Score Improvement
Dyspnea Scores (OASIS) 80.7 92.4 11.7 83.6 86.6 89.5 82.7
Dyspnea Weighted Points       1.4 2.9 4.4 1.0
60-Day ACH Scores (Claims) 15.0 10.3 4.7 13.8 12.7 11.5 13.0
60-Day ACH Weighted Points       6.7 12.8 19.5 11.2
Care of Patients Scores (HHCAHPS) 89.0 94.0 5.0 90.3 91.5 92.8 91.0
Care of Patients Weighted Points       1.6 3.0 4.6 2.4

A 50% improvement in your ACH score within the achievement range generates 12.8 TPS points versus 2.9 and 3.0 for Dyspnea and Care of Patients, respectively. Also, a two percentage point improvement in scores over the achievement threshold produces over double the weighted points between Dyspnea (1.0 pts) compared to Care of Patients (2.4 pts) due to the tighter range of scores.

There is a lot to learn regarding the new HHVBP program and having an extra year to prepare will definitely help. Check out the webinar Zeb Clayton and I presented on HHVBP just prior to when the final rule was released on the details of the program and what we gleaned from the CMMI 5 year HHVBP demonstration. Look for opportunities to improve your HHVBP measure outcomes and TPS scores throughout 2022 to position your agency to be successful during the first performance year of CY 2023.

SHP customers can continue utilizing our VBP National Preview Report throughout 2022 to review their performance. If you are not a customer today, please reach out to us to schedule a free demo of our SHP for Agencies solution and ask about HHVBP reporting.

About the Author
Chris Attaya
Chris Attaya
VP of Product Strategy
With more than 30 years of experience in the home health and hospice industry, Chris is responsible for product development and helping clients achieve increased operational and financial performance.