Home Health Value Based Purchasing Resources

The group reviewed several resources recently released by CMS for the implementation of the expanded Home Health Value Based Purchasing model in CY2023:

• Achievement Thresholds and Benchmarks
• HHVBP Model Guide
• HHVBP QAPI Processes to Support Improvement
• HHVBP Risk Adjustment Process
• Calculating Total Normalized Composite (TNC) Change Measures

LeadingAge will be offering deep dive webinars in the fall on the model, any proposed model changes from the CY2023 Home Health Proposed Rule, and practical next steps for implementing the model at an agency level. The webinar would combine financial, clinical, and operational perspectives. LeadingAge will also recap anything finalized in the CY2023 Home Health Final Rule expected in November 2022. Members were particularly interested in any deep dive on the quality measures used in the model.

Home Health Medicare Advantage

Medicare Advantage (MA) has been of particular interest with home health members. Nicole Fallon joined the group to share resources available exclusively to LeadingAge members to help with managed care contracting. The Center for Managed Care Solutions & Innovations is LeadingAge’s clearinghouse for information, resources, networking, and assistance about the relationship between managed care, both Medicare and Medicaid, and post-acute and long-term services and supports providers. Members can find information, education and tools providers need to participate in managed care, integrated service delivery and alternative payment models, such as accountable care organizations and/or bundled payments.

Members discussed the unique challenges of home health agency contracts with managed care. Nearly all members struggled with the payment rates in MA and there was a consensus that plans were unwilling to negotiate rates due to the over saturation of home health providers in nearly all markets. Many members felt only very large ageinces could sustain working with MA on a regular basis. Several members had both Medicaid and Medicare managed care in their states.

To improve rates, members have reached out to elected officials with very limited success. Nicole encouraged members to couch conversations with legislators regarding the unfair contracting processes in terms of beneficiary impact. Without adequate reimbursement agencies could not sustain services leading to access issues for beneficiaries.

Some providers were seeing a shift in payment methodology with some plans moving to the Patient-Driven Groupings Model or pay for performance/value-based purchasing. Still, most were seeing per visit rates well below Medicare fee for service rates. Members were also seeing an increase in Additional Documentation Requests, in some cases for nearly every claim. Some had been paid only a percentage of their contract then audited and asked to return overpayments. This has become an increasing problem and priority for LeadingAge. Staff are continuing to work with policymakers to hold MA plans accountable for quality of care and access to services like home health.

Policy Update

LeadingAge Met with CMS Payment Policy Staff: Last Friday, LeadingAge staff met with payment policy staff at the Centers for Medicare and Medicaid Services (CMS) to share feedback from members and invite staff to join future discussions with members. LeadingAge shared concerns about inconsistencies in the Notice of Admission (NOA) billing fixes between Medicare Administrative Contractors (MACs). CMS said a fix to NOA billing was issued on May 23rd, but it could take time for billing systems to be updated by the individual MACs. CMS staff said they would follow up with internal claims processing teams to make sure all MACs have the information and are working to implement the fixes. Finally, LeadingAge staff invited CMS to join future calls for the Home Health and Hospice Member Networks to listen to provider feedback on proposed regulations.

OASIS-E Update: The Office of Inspector General announced a reprot coming next year on falls based on the new claims measure that started publicly reporting in April. The report will use Medicare claims to identify hospitalizations due to falls with major injury and the analysis will look the extent to which falls were reported on OASIS. The report will include a description of the beneficiary characteristics who did not have falls reported in OASIS as well as characteristics of home health agencies that have low falls reporting rates.

Legislative Update: Unfortunately, it is unclear if there will be a package with additional COVID relief including access to testing and vaccines. The Congressional focus is on gun violence which will likely take up much of the early summer focus. Congress is also continuing to work on mental health packages and appropriations legislation.