With the Home Health Final Rule for CY 2016 now posted on the Federal Register, Home Health Agencies (HHAs) were looking forward to getting more information during the Centers for Medicare and Medicaid (CMS) Home Health, Hospice & Durable Medical Equipment Open Door Forum (ODF) on November 4th, 2015, especially in regards to Home Health Value Based Purchasing (HHVBP). There are still open questions not addressed in the final rule for this program that begins January 1, 2016.
During the question and answer session at the end, however, it was clear that more information is needed. CMS speakers noted that the numerators and denominators for at least 4 of the measures have not yet been shared and it was unclear whether the outcome measures would be based on Traditional fee-for-service (FFS) Medicare or on all Medicare and Medicaid patients as is currently reported on Home Health Compare (HHC). CMS was not able to explain how agencies will sign in to the portal, and which details will be requested, either. With just more than 30 days before agencies’ performance will be measured in nine states, it would be helpful to know this now, although CMS said there will be a follow-up call on December 2nd with more information.
To be fair, the final rule had many important updates. Home Health Agencies will have a slight reduction in the penalty rates for 2 of the 5 years. There will also be a delay in the data collection for the new measures until the third quarter of 2016. The original 29 HHVBP measures were reduced to 24 process measures that were either topped out or were already reported in the Outcome and Assessment Information Set (OASIS). In updating the four-equation case-mix model for CY 2016 using 2014 data, there were a few changes to the point values for the variables in the four-equation model. The thresholds for calculating the severity levels of the clinical and functional domains have also changed slightly. See this link for these changes compared to the prior year.
Also interesting to me is that agencies in the HHVBP states will need to track performance twice: once against their state peers for HHVBP measures, and again against the national benchmark for the Quality of Patient Care and HHCAHPS Star Ratings. This means that even though your Star Ratings may look great, your state ranking may not. Using the CMS data on three measures posted on HHC in October 2015, some states are as much as 5 percentage points higher or lower than the average.
HHC Scores Posted October 2015
|Managing Daily Activities||National||MA||MD||NC||FL||WA||AZ||IA||NE||TN|
|Improvement in Ambulation||63.5%||66.2%||65.3%||62.9%||67.1%||58.2%||59.4%||64.5%||63.0%||64.3%|
|Improvement in Bed Transferring||58.9%||63.0%||62.6%||59.8%||60.9%||55.6%||57.1%||60.3%||61.0%||59.1%|
|Improvement in Bathing||68.5%||69.1%||70.5%||65.2%||73.6%||63.4%||68.4%||70.5%||67.4%||68.9%|
|Variance from National||National||MA||MD||NC||FL||WA||AZ||IA||NE||TN|
|Improvement in Ambulation||2.7%||1.8%||-0.6%||3.6%||-5.3%||-4.1%||1.0%||-0.5%||0.8%|
|Improvement in Bed Transferring||4.1%||3.7%||0.9%||2.0%||-3.3%||-1.8%||1.4%||2.1%||0.2%|
|Improvement in Bathing||0.6%||2.0%||-3.3%||5.1%||-5.1%||-0.1%||2.0%||-1.1%||0.4%|
There is a lot to consider when determining your approach to improving overall quality including best practices, and prioritizing which measures to work on. First, however, agencies need to know what all the rules and calculations will be. They will have to wait until December.