CMS Implementation of Home Health Value Based Purchasing Program
November 17, 2015 09:24 AM
The Centers for Medicare & Medicaid Services (CMS) is moving along quickly with the January 1, 2016, implementation of the Home Health Value Based Purchasing Program (HHVBP) as outlined in the Final Rule issued as part of the 2016 Home Health Prospective Payment rule. Recently, the National Association for Home Care & Hospice (NAHC) met with CMS officials to discuss a multitude of open implementation issues. Home health agencies in the nine states are anxiously awaiting more detailed information on the pilot program that promises to be the most significant Medicare change since the 2000 implementation of prospective payment.
At this point, there are threshold questions yet unanswered by CMS while the HHVBP is only seven short weeks away. Among the crucial questions in need of response is what home health population data will be used to determine an agency’s baseline performance and performance year score. In the CMS meeting, the question was raised as to whether the OASIS and HHCAPS data from the Medicare Fee-for-Service population would be used in HHVBP or whether the data from Medicare Advantage, Medicaid, and other patients would be included. Currently, Home Health Compare and the Star Rating systems use all such data. The Final Rule indicates that the data from Medicare “enrollees” would be used. Officials at the meeting indicated that it is most likely that the HHVBP data will be confined to Medicare fee-for-service beneficiaries. However, that standard appeared far from certain, particularly given CMS’ current combination of all data in its public reporting on HHAs.
Another important issue is when the affected agencies will receive the “achievement threshold” and “benchmark” information that is essential for providers to understand what the performance targets are relative to the myriad of measures in play in HHVBP. Until such information is known, providers cannot determine how their performance compares to those measures and which areas need the most improvement effort in order to gain a financial bonus in HHVBP or avoid a penalty. CMS officials indicate that such information will be available no earlier than April 2016 as it will take time to process the 2015 baseline data that covers all of 2015.
CMS officials indicated that they would be providing responses to all questions through their HHVBP website so that all participants have access to the information. Questions can be submitted to CMS through HHVBPquestions@cms.hhs.gov. In addition, CMS has asked that NAHC remind HHAs in the affected nine states to email their primary point of contact along with CCN to HHVBPquestions@cms.hhs.gov so that CMS can register them for the December 2, 2015, webinar and establish access to the HHVBP web portal that will be used to see their performance reports and enter New Measures.