Payment Changes Only One Part of CY 2017 Final Rule

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Rhonda Oakes By Rhonda Oakes 
Regulatory Analyst, Change Healthcare
Clinician discussing Medicare payments for home health care

The dust has settled and transmittals have begun to post offering additional instructions and guidance around the CY 2017 final rule for home health agencies. The Centers for Medicare & Medicaid Services (CMS) is reducing Medicare payments to home health organizations by 0.7%, or $130 million in calendar year 2017. But lost in the late October CY 2017 final rule were updates to the Home Health Quality Reporting Program (HH QRP) and the Home Health Value-Based Purchasing model (HH VBP) that you may not have seen.

In regard to the payment update, 2017 rates reflect:

  • 5% increase in home health payment
  • 3% decrease in rebasing adjustments to the national, standardized 60-day episode payment rate, national per-visit payment rate and non-routine medical supplies conversion
  • 97% decrease for case-mix growth

Home Health Quality Reporting Program (HH QRP) Update

CMS continues to implement portions of the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act), which requires quality and other data to be publicly reported by home health organizations, skilled nursing facilities, inpatient rehabilitation facilities and long-term care hospitals.

Beginning with payment determination for CY 2018, CMS adopted these measures to meet the IMPACT Act requirements. The first three will be calculated using Medicare claims data, while the fourth will be assessed using Outcome and Assessment Information Set (OASIS) data.

  1. Potentially Preventable 30-Day Post-Discharge Readmission Measure for Post-Acute Care Home Health Quality Reporting Program
  2. Total Medicare Spending per Beneficiary – Post Acute Care Home Health Quality Reporting Program (MSPB-PAC HH QRP)
  3. Discharge to Community- Post Acute Care Home Health Quality Reporting Program
  4. Drug Regimen Review Conducted with Follow-Up for Identified Issues-Post-Acute Care Home Health Quality Reporting Program
    • A patient assessment-based, cross-setting quality measure was adopted as to meet the IMPACT Act requirements, with data collection beginning January 1, 2017.
    • The measure assesses whether home health agencies (HHAs) are responsive to potential or actual clinically significant medication issue(s) when such issues are identified.
    • The measure will be applied uniformly across post-acute settings. For home health, the measure requires the following questions to be addressed at the specified time points:
      • M2001 Drug Regimen Review Item
      • M2003 Medication Follow-up Item
      • M2005 Medication Intervention Item

Speaking of OASIS data, home health organizations that do not submit quality data will see a 2% reduction in their annual payment update. The compliance threshold for data submission is rising to 90% beginning with the reporting period for CY 2017 (July 1, 2015-June 30, 2016).

CMS has removed 28 Home Health Quality Initiative (HHQI) measures. Click here to see the list and the reasons these measures are no longer collected.

Finally, CMS confirmed that six process measures will be removed from HH QRP beginning with the CY 2018 payment determination. CMS clarifies that measures no longer included in the HHQI or removed from the HH QRP may still appear on OASIS—removal from HH QRP does not necessarily mean removal from a future OASIS. Therefore, if an item was used for a previously established purpose no longer related to the HH QRP, and if it’s still collected on the OASIS, data for it will remain available to home health agencies through the CASPER on-demand reports to help monitor and improve quality efforts.

Home Health Value-Based Purchasing Model

We’ve previously reported on the Home Health Value-Based Purchasing (HHVBP) Model that began on January 1, 2016, in Arizona, Florida, Iowa, Maryland, Massachusetts, Nebraska, North Carolina, Tennessee and Washington. Payments will be adjusted upward and downward based on performance against six measures reported on OASIS and HH CAHPS.

As part of the final rule, CMS announced these changes to the HH VBP model:

  • Calculate benchmarks and achievement thresholds at the state level rather than the level of the size cohort. Benchmark definition revised to refer to the mean of the top decile of Medicare-certified organization performance on the specified quality measure during the baseline period calculated for each state
  • Require a minimum of eight organizations in any size cohort
  • Increase the timeframe for submitting new measure data from seven calendar days to 15 calendar days following the end of each reporting period to account for weekends and holidays
  • Remove these four measures:
  1. Care Management: Types and Sources of Assistance
  2. Prior Functioning ADL/IADL
  3. Influenza Vaccine Data Collection Period
  4. Reason Pneumococcal Vaccine Not Received from the set of applicable measures
  • Adjust the reporting period and submission date for the Influenza Vaccination Coverage for Home Health Personnel measure from a quarterly submission to an annual submission
  • Implement the recalculation and reconsideration processes

The bipartisan message from lawmakers continues to support the move toward patient centered care, the need for interoperability, and above all else, that quality rather than quantity will be reimbursed. It leaves the idea of “quantity” in the past. These are key principles of healthcare reform. It’s important that home health agencies manage operations and resources to help control the cost of care provided and document outcomes that demonstrate that quality care was delivered. And yes, all of this must be in line with reimbursement rates in order for your agency to survive.

As a new administration takes office, we’ll monitor closely for a changing regulatory landscape. We’re prepared and ready to take on the proposed home health groupings model if it becomes finalized in a future regulatory announcement.

Working together with our customer workgroups, our teams continue to monitor regulations affecting our customers to determine the functionality needed to help meet the regulations.

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