CMS Proposes $ 310 Million In-Home Payments Increase and HHVBP Nationwide Expansion

The U.S. Centers for Medicare & Medicaid Services (CMS) on Monday proposed plans to expand the home health value-based purchasing model (HHVBP) nationwide by the start of l ‘next year. The agency did so in its proposed payment rule for 2022.

In addition to the expansion of the HHVBP, CMS has proposed to increase Medicare payments to home health agencies by 1.7% next year, which equates to an increase of about $ 310 million. The payment rule proposed last year for 2021 included a 2.6% increase, with the final rule lowering it to 1.9%.

In addition to the HHVBP and a standard rate increase, the payment rule proposed on Monday also changed the formal conditions for participation in Home Health (CoP) and provided an overview of CMS’s plans for future adjustments to the Focused Cluster model. on patients (PDGM).

The CMS Innovation Center developed the HHVBP demonstration – one of the most successful alternative payment models ever – with the aim of creating financial incentives for better quality of care. First implemented in 2016, the demo is currently active in nine randomly selected states.

“Homebound Medicare patients face a unique set of challenges and barriers to getting the care they need,” CMS administrator Chiquita Brooks-LaSure said in a statement. “This proposed rule would streamline service delivery and prioritize quality over quantity – at a time when Americans need it most.”

The CMS Innovation Center under the Trump administration previously revealed its intention to expand the HHVBP in early 2021. Since its implementation, the HHVBP has resulted in an average 4.6% improvement in health agency quality scores. at home as well as an average annual savings of $ 141. million to Medicare, according to CMS

“[HHVBP] is a great example of how the Innovation Center can design successful models that both improve quality for Medicare beneficiaries and reduce costs, ”said Brad Smith, the former head of the center, in January . “Over the past year, we have taken a data-driven approach to evaluate all models of the Innovation Center, and we are delighted that the HHVBP has met our standard of excellence in expansion, such as as defined by Congress. “

The expanded HHVBP model’s first performance year would be CY 2022, with quality performance data from that year used to calculate payment adjustments under the expanded model in CY 2024, CMS explained.

The agency is also proposing to end the existing model a year earlier for current participants, meaning CMS would not use CY 2020 data to make payment adjustments for next year.

“The proposed 387-page rule by CMS is a combination of major and minor changes in the payment model for home health care and [CoPs], as well as the expected expansion of the HHVBP and the establishment of improved survey and certification standards for hospices, ”said William A. Dombi, president of the National Association for Home Care & Hospice (NAHC), in a statement. release shared with Home Health Care News.

PDGM developments

In addition to expanding the HHVBP and increasing the Medicare home health care reimbursement rate, CMS has said it will not take any action to change the behavioral adjustment of 4.36% of the PDGM – at least. not yet.

“CMS is not proposing any specific method or behavioral assumption payment adjustment in this proposed rule,” he said.

Instead, the published proposed rule included “preliminary scans” of the first year of the PDGM, including data on source of admission, timing, clinical clustering, level of functional impairment and more. CMS also offered insight into how it analyzed the differences between supposed and actual behavior changes.

The agency said it “is seeking comments on the method described and other possible methods to determine the impact of behavioral changes on estimated overall spending.”

The bipartite budget law of 2018 required that the PDGM be budget neutral. However, spending on home health care in the 2020 implementation year was actually down about 21.6% from projections, according to an August analysis by Dobson DaVanzo & Associates. .

It’s no surprise that CMS chose to make some major changes to the PDGM.

In April, regulators highlighted how the implementation of patient-centered payment models resulted in an unintentional increase in payments to skilled nursing facilities (SNFs) of about 5%, or $ 1.7 billion, during fiscal year 2020. Despite the unintentional overpayment, CMS said it plans to delay any remediation as the COVID-19 emergency is complete and more reliable data is available.

Other updates

In its proposed rule, CMS also launched plans to create a Low Usage Payment Adjustment (LUPA) add-on for occupational therapists (OT). Generally speaking, given that occupational therapists can now perform assessments and certify home health services, CMS offers an additional factor to accommodate that first qualified occupational therapist visit during LUPA periods.

On top of that, the proposed rule would adjust the home health quality reporting program, removing some measures that would increase the burden on providers, the agency said.

“For good measure, CMS has tweaked the home health quality metrics and added home infusion therapy adjustments,” Dombi said.

While the expansion of HHVBP is large and remarkable, many details of the proposed rule are measured and subtle. This is most likely the case due to the Public Health Emergency (PHE) and how it has disrupted the home health industry.

Among the details, the proposed rule would remove the OASIS-based measure “Medication Education of All Medications Provided to Patient / Caregiver During All Episodes of Care”. CMS proposes to do this because measurement performance is high enough among home care agencies that meaningful distinctions between performance can no longer be made.

In addition, CMS is proposing to make permanent selected regulatory general exemptions related to the supervision of home helpers and the use of telecommunications that were issued during the COVID-19 public health emergency.

“We believe that the current requirement for a 14-day on-site supervisory visit when a patient receives qualified services is an important element in assessing the quality of care and services provided by the [home health] help, and to ensure that support services meet the needs of the patient, ”said CMS. “Although we propose to allow this flexibility of telecommunications, we expect that in most cases, [home health agencies] would plan to complete the 14-day supervisory assessment during an on-site, in-person visit, and that the HHA would use the interactive telecommunications systems option only for unforeseen events that would otherwise interrupt scheduled in-person visits.

The full rule proposed for 2022 can be viewed here.