CY 2023 Home Health Prospective Payment System Proposed Rule Update

CMS staff provided an overview of the CY2023 Home Health Perspective Payment System proposed rule issued June 16^th, 2022. The proposed rule would provide a 2.9% proposed market basket increase. The rule also proposes a permanent cap of 5% on negative wage index changes. The proposal includes changes to case mix weights, comorbidity adjustments, LUPA thresholds and functional impairment levels. The rule provides Home Infusion Therapy rate updates as well.

Most notable, CMS has also proposed a permanent adjustment of -7.69% to the 30-day period payment to account for difference between assumed behavior and actual estimated aggregate costs associated with the transition from the former payment system to the Patient Driven Grouping Model. The overall aggregate impact is estimated to be -4.2% in CY2023. Additionally, CMS is asking for comments on how to implement a temporary adjustment of $2 billion based on overpayments in CY2020 and CY2021.

The proposed rule also includes a request for information on the collection of telehealth data on home health claims to better understand beneficiary level use of such services. Comments on the proposed rule are due August 16^th. To read a full recap of the rule click here.

Hospice Quality Reporting Program (HQRP) Updates

August 2022 Care Compare Refresh

CMS provided an update on the August 2022 Hospice Care Compare refresh. This refresh will include two new claims-based measures, which will be publicly displayed for the first time in August:

• Hospice Care Index (HCI)
• Hospice Visits in the Last Days of Life (HVLDL)

As the HQRP tip sheets released in December 2021 stated, these two measures will include the most recent 8 quarters worth of data but exclude Q1 and Q2 of 2020. The HVLDL measure will replace the current “Hospice Visits When Death Is Imminent” measure. Hospices can now access the latest Provider Preview Reports for the August 2022 Care Compare refresh via the CASPER application.

As a reminder, CMS had originally planned to release these two new claims-based measures in the May 2022 Care Compare refresh but ultimately delayed the public release to August 2022. LeadingAge confirmed with CMS staff that the decision to delay the inaugural public display of the two new hospice claims-based measures was based on technical errors in the calculation of the measure scores. CMS has since corrected these issues and hospices can expect to see these two new measures on their preview reports, as well as on the CMS Care Compare/Provider Data Catalog sites, related to the upcoming August 2022 refresh.

FY 2023 Hospice Wage Index Proposed Rule

The comment period for the FY2023 Hospice Wage Index proposed rule closed May 31, 2022. CMS is working to review and incorporate the comments received into the final rule which will be published later this year.

Reconsideration for FY2023 Hospice Quality Reporting

Hospices who have not reported data for the HQRP will receive official notice for non-compliance in mid-July. This notification will come from the Medicare Administrative Contractor (MAC) and through the CASPER application. As a reminder, hospices who do not submit will receive a 2% Annual Payment Update penalty. In FY2024, this penalty will increase to 4%.

Upcoming Resources

In July, Swingtech will issue a quarterly informational email for hospice providers on the HQRP. This outreach communication can be found on the HQRP Requirements and Best Practices webpage in the downloads section. If providers would like to receive Swingtech’s quarterly emails (or update their email) they can email QRPHelp@swingtech.com. Providers should include their facility name and CMS Certification Number (CCN) along with any requested updates.

CMS will also be publishing two new videos on the HQRP, one will be a general overview of quality reporting for hospices and the second will look at the Hospice Care Index. These videos will be available in July on the Hospice QRP Announcements & Spotlight webpage.

Finally, CMS is planning to release a technical report on the Hospice Item Set as well as a quality measure user manual in July. LeadingAge will keep members informed of these new resources as they become available.

Home Health Quality Reporting Updates

OASIS Updates

On May 16, CMS released a draft Guidance Manual for the OASIS-E version of the OASIS data set. The implementation date for OASIS-E is January 1, 2023, however it is still in OMB clearance. On May 23, CMS updated the OASIS Static Q&AS on the QIES Technical Support Office webpage. The Q&As cover four categories of questions looking at applicability, the comprehensive assessment, follow up assessments and the OASIS data set form and items.

July 2022 Home Health Compare Refresh

Preview Reports reflecting results from the Home Health Care CAHPS (HHCAHPS) Survey, OASIS, and claims-based measures are not available on iQIES. Data will be updated on Medicare’s compare tool Care Compare in late July 2022 and includes star ratings updates.

CY2023 Home Health Proposed Rule Quality Updates

Included in the CY2023 Home Health proposed rule are several quality updates. Specifically, staff shared that CMS has proposed to end the current suspension of the collection of OASIS data on non-Medicare and non-Medicaid patients and require home health ageinces to report all-payer OASIS data for the purpose of the Home Health Quality Reporting Program (HHQRP) beginning in CY2025. CMS is also requesting feedback on health equity issues in home health and the development of a structural measure concept. Comments on the proposed rule are due August 16^th.

Expanded Home Health Value-Based Purchasing (HHVBP) Model Update

CY2023 Home Health Proposed Rule HHVBP Updates

In the CY2023 Home Health Proposed Rule, CMS proposes to change the baseline HHVBP year from CY2019 to CY2022 for the performance year starting in CY2023. CMS is also requesting public comments on policy changes to the expanded model on the topic of health equity. Specifically, CMS is requesting comments on whether they should consider incorporating adjustments into the expanded HHVBP Model to reflect the varied patient populations that agencies serve around the country and tie health equity outcomes to the payment adjustments they make based on agency performance under the Model.

New Resources for HHVBP

CMS staff discussed new resources availabe on the HHVBP webpage. The latest resources included:

• June newsletter and updated FAQ document
• Model guide that acts as a “how to” manual for implementing HHVBP
• Composite measure guide for two OASIS based composite measures
• Resource discussing the risk adjustment process for the model
• Podcast on leadership and communications for implementing the model
• Instructional video explaining how to utilize all the resources provided by CMS

The technical assistance team will also be issuing a sample interim report and final report in late June. In August the team will be hosting a webinar to walk providers through how to read these reports.

Home Health CAHPS Survey Update

The exemption form is now available for CY2024 on the Home Health CAPHS website. As a reminder, exemption is available for agencies with 59 or fewer patients from April 2021 through March 2022. Exemptions forms will be due March 31, 2023.

On July 1, a new issue of the HHCAHPS Coordination Team Quarterly Review (CTQR) will be posted on the HHCAHPS website. These newsletters are an opportunity to learn more about the program through data insights and provider tips and tricks.

The HHCAHPS team reminded providers that the data submission deadline for the quarter is July 21 and that home health agencies have a responsibility to review data submission reprots to make sure data was successfully submitted via the dashboard on the Home Health CAHPS website. The HHCAHPS team encouraged home health providers thinking of changing vendors to reach out to RTI at hhcahps@rti.org or 866-354-0985.

Additional Audience Questions

A provider asked for clarification on when CMS would provide updated achievement thresholds and benchmarks if the current proposal to change the benchmark year from 2019 to 2022 is approved. CMS responded that if the proposal is finalized providers would receive updated achievement thresholds and benchmarks in the summer of 2023.

Another provider shared concerns that their agency was already working to implement improvement plans based on the CY2019 achievement thresholds and benchmarks which were issued in May. Changing the baseline year will require providers to redo a lot of work. The provider asked for clarification on CMS’ decision making and if they considered the impact on agency currently preparing for the expanded model. CMS staff referred participants to the proposed rule which includes a detailed explanation for the decision and added the decision came from the effects of pandemic on several of the measures used in the expansion model. CMS wanted to make sure data was most current and not per-pandemic. CMS felt the proposed change in baseline year was the best for the majority of agencies.

One association asked CMS if they were planning to issue an update to the January 2022 report on home infusion therapy services. The individual noted that there were just five home infusion therapy providers which accounted for 80% of the supply and 50% of visits for the program. It was also noted that there were potential patient access issues in light of recent announcements that two home infusion providers were downsizing and closings dozens of facilities. CMS responded that they are continuing to monitor data and will be working to develop more public facing documents to showcase the data on the program on a yearly basis. CMS is also monitoring the recent developments in the home infusion market and talking internally about developing more access to the program.

Several electronic medical record developers pressed CMS about data specifications for the OASIS-E implementation. The current version available is from April 2020 and there have been several updates to the instrument since that time. There are only six months until implementation and developers stressed that time was needed to make modifications and also to allow providers time to educate clinicians on the new systems. CMS said they were working to get those specifications out to vendors but at this time did not have a date for the release.

Finally, one provider had a question regarding hospice Care Compare. With CMS’ decision to not release the two new claims based measures until August 2022, the site now states that data was suppressed upon request from the agency. The provider was concerned that this is misleading for patients and families seeking serivces. CMS clarified that an additional update to the footnotes is being published soon to clarify why data was suppressed.