Closely Monitor Value-Based Purchasing for Home Health
Posted On: September 29th, 2015
Former Vice President, Product Marketing and Strategy, McKesson (Retired)
Home health organizations should be paying close attention to the Home Health Value-Based Purchasing (HHVBP) Model, which the Centers for Medicare & Medicaid Services (CMS) announced in July. The demonstration project in nine states puts additional quality metrics in place, with performance creating the potential of risk or reward of 8% by 2021.
McKesson was pleased to provide comments on the model, sharing the views of our valued customers and reflecting on the impact in the vendor space. While we strongly support the drive forward to value-based care and value-based reimbursement, we believe there is a balance to be maintained in the process. To that end, we want to avoid unnecessary burden and question the need for the addition of new measures outside of the existing data collection vehicles. The proposed payment adjustments are far greater than those being used by the Hospital Value-Based Purchasing (VBP) Program.
Here’s a look at the major components of the proposal and a summary of our comments to CMS:
Reimbursement rates. Under the proposal, Medicare-certified home health organizations in nine geographically diverse states will operate under enhanced quality measures that CMS believes will bring better patient care. Based on performance against these measures, the agency proposed to increase or decrease payments by as much as 5% in 2018 and 2019, 6% in 2020, and 8% in the final two years.
We believe that the adjustments should be more reflective of previous experience and demonstrations, such as the hospital VBP with its maximum payment adjustments ranging from 1% to 1.5% over its three-year span.
New quality measures. CMS has proposed four new measures that cover 1) advanced care planning; 2) adverse events for improper medication administration and/or side effects; 3) influenza coverage for home health organization personnel; and 4) shingles vaccine received by patients.
The industry already uses 25 of the proposed quality measures. These have a record of reliability and risk adjustment, so we don’t believe additional measures are needed as a part of this demonstration project. However, if CMS continues with this policy, we expressed hope that measures 1, 2 and 4 could be incorporated into existing reporting documents, such as OASIS, to lessen the administrative burden on organizations. Likewise, we believe the influenza vaccination should be incorporated into the pending Conditions of Participation in Medicare and Medicaid for Home Health Agencies.
Calculating Total Performance Score (TPS). Under the proposal, CMS will compile an organization’s TPS using data from OASIS reports, Medicare claims, Home Healthcare Consumer Assessment of Healthcare Providers and Systems Survey (HHCAHPS) and data reported directly to CMS.
Only OASIS scores are generally part of electronic health records systems, so vendors would need to connect the other components of the TPS from other data sources. We requested that CMS explore ways to ensure vendors have timely access to this data, so it can be compiled in a way truly useful to our customers.
We will be carefully watching this proposal, as comments are compiled and revisions are made to the Home Health Value-Based Purchasing Model . You should pay close attention, too, because the effects likely will be wide-ranging for our industry.
Is your organization prepared to transition to value-based care? Learn why the HHS is shifting nearly one-third of all Medicare payments to value-based care models that stress quality over volume.