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CMS Releases Extended Home Health Care Value-Based Purchasing Model (“HHVBP”) Guidance | Proskauer – Dissertation on healthcare law


On November 2, 2021, the Centers for Medicare & Medicaid Services (“CMS”) released a “Final Rule” that advances the shift from paying for Medicare home health services based on volume to a system that pays according to value. In addition to other issues, the final rule extends the HHVBP model from 9 states to 50.

The new rule stems from a decade of CMS Innovation Center experimenting with alternative payment models for home health care, all launched with the goal of encouraging improved quality of care for home care patients. The HHVBP model was initially piloted in 9 states and has resulted in a reduction in acute hospitalizations and stays in skilled nursing facilities. Thus, CMS has determined that extending the model will further reduce Medicare spending and improve quality. Effective January 1, 2022, the HHVBP model will apply to all Medicare-certified HHAs in all 50 states, territories and the District of Columbia. In this blog post, we highlight the key components of the extended HHVBP model.

Note that CY 2022 will be a pre-implementation year with CMS providing HHAs with training and resources to prepare for success. CY 2023 will be the first performance year with payout adjustments occurring in CY 2025. Payout adjustments will be based on the performance of each HHA on a set of quality metrics in a given performance year against other HHAs grouped together in the same cohort.

Cohorts are identified based on the unique nature of HHA beneficiaries served in the year leading up to the performance year, with allocation based on large or small volume HHAs nationwide of size and quality. similar. The adjustments will range from -5% to + 5% of Medicare fee-for-service payments.

Specifically, payment adjustments are based on the Total Performance Score (TPS) of each HHA in a given performance year, which includes performance on: (1) a set of metrics reported through the set of ” Outcome and Evaluation Information (OASIS), (2) Completed Health Care Provider and Home Health Care Systems (HHCAHPS) Assessment Surveys, and (3) Measurements Based on complaints (e.g. quality measures do not count: (i) for patients who did not respond at the start of care or at the resumption of care, (ii) if the HHA has less than 20 qualifying episodes of quality and (iii) for any patient receiving Medicare Advantage or Medicaid.

The expanded model will use benchmarks, achievement thresholds, and improvement thresholds based on CY 2019 data to assess achievement or improvement in HHA performance on applicable quality metrics. Competitive HHAs who demonstrate they can provide better quality care in a given performance year against a benchmark year and against their peers nationwide (as defined by cohorts of larger volume versus smaller volume), will be eligible to have their PPS health care benefit claims final. amount of the adjusted payment greater than the amount that would otherwise be paid. Payment adjustments for a given year will be based on the GST calculated for performance two years previously. All HHAs certified to participate in the Medicare program before January 1, 2022 will be required to participate and will be eligible to receive an annual TPS based on their CY 2023 performance.

Note that while the HHVBP model does not apply to Medicaid or commercial patients, it does provide a path and format to use in these markets, as most payers are moving towards paying for value rather than volume.

You can find more information on the HHVBP CMS template at https://innovation.cms.gov/innovation-models/expanded-home-health-value-based-purchasing-model and will be updated with further guidance in 2022.

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