It’s official: Providers around the world will soon be subject to the Home Health Value-Based Purchasing Model (HHVBP). The expanded initiative’s first year of performance – recognized as one of the most successful alternative payment models ever – will be calendar year 2023.
The US Centers for Medicare & Medicaid Services (CMS) on Tuesday released the home health care final payment rule in 2022. In addition to cementing the nationwide expansion of HHVBP, the rule sets an increase of 3, 2% of the home health insurance rate for next year, an increase of about $ 570 million.
The agency originally proposed a 1.7% increase in June.
“Today, [CMS] Acted to improve home health care for the elderly and people with disabilities through a final rule that would speed the shift from paying Medicare home health services based on volume to a system that pays for value, ” the agency wrote in a statement.
With HHVBP, CMS is finalizing policies that lock in pandemic era blanket waivers related to home help supervision and telecom use during assessment visits.
“As we finalize the limited use of telecommunications technology when fulfilling the 14-day supervisory visit requirement when a patient receives qualified services, we expect that in most cases , the [home health agency] would plan to conduct the 14-day supervisory assessment during an in-person on-site visit, ”CMS said. “And that the [agency] would use the interactive telecommunications systems option only for unforeseen events that would otherwise disrupt scheduled in-person visits.
Tuesday’s rule also featured an update to payment rates for home infusion therapy services and finalized a recalibration of parts of the Patient-Centered Groups (PDGM) model.
Specifically, CMS is fine-tuning case weights, functional levels, and comorbidity adjustment subgroups while maintaining the 2021 Low-Use Payment Adjustment (LUPA) thresholds for 2022.
Accelerate the transition to value
The CMS Innovation Center launched the HHVBP model as part of a demonstration project in nine states in 2016 to assess whether policymakers could improve the quality and delivery of home health care through financial incentives.
In 2018, the first year that providers were exposed to financial incentives, the maximum payment adjustment was 3%. This gradually increased to a maximum adjustment of 6% last year.
Over the past decade, CMS and its innovation hub have launched more than 50 alternative payment models. Only four ended up meeting the expansion requirements, with HHVBP being one of the most successful experiments.
In fact, the HHVBP has resulted in an average annual savings of $ 141 million for Medicare since its implementation in 2016, according to CMS.
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“CMS is committed to helping people get the care they need, where they need it,” CMS administrator Chiquita Brooks-LaSure said in a statement. “This final rule will improve the delivery of home health services for people with Medicare. It will also improve our data collection efforts, helping us identify health disparities and advance health equity. “
In its final rule for 2022, CMS is moving forward with its plan to implement an HHVBP adjustment capped at 5%. While 2023 will be the first year of performance, 2025 will be the first year of payment.
CMS is also moving forward with its plan to scale up 2020 for home health agencies already competing in the nine demonstration states. Performance data for this year will also not be released.
“We are designating CY 2022 as a pre-implementation year in response to a number of comments we have received” CMS explained in 528 page final rule.
While CMS slightly adjusts the HHVBP timeline from its June proposal, the agency primarily retains the performance criteria and competition framework.
Similar to the demonstration in nine states, home health agencies will compete on the basis of certain improvement and achievement metrics derived from OASIS elements, claim data, and vendor assessment surveys and systems. home health care (HHCAHPS).
Unlike the demo, however, the agencies will be divided into “large” and “small” cohorts, defined by whether or not they are exempt from submitting the HHCAHPS survey. Also, unlike the demo, the agencies will compete on a national basis – not exclusively against their counterparts in the same state.
Following the proposed expansion, several home health officials have urged CMS to better judge providers caring for highly complex patients who are unlikely to show signs of improvement. Others called on the agency to somehow consider providers’ ability to address social determinants of health (SDoH).
CMS refused to adjust HHVBP based on these requests.
“We have no evidence to suggest that [agencies] that care for beneficiaries with higher social risk factors would be reduced [fee-for-service] payments under the expanded model, ”the agency wrote in the final rule.
CMS also refused to switch to a shared savings approach to improve incentives.
“We appreciate this comment, but it is outside the scope of our proposals on expanding the HHVBP model,” CMS noted.
CMS is also updating the Home Health Conditions of Participation (CoP) to allow an occupational therapist to perform the initial home health assessment visit and complete the comprehensive assessment under the Medicare program, but only when occupational therapy is part of the home health care plan.