LeadingAge submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the following sections of the 2016 Home Health Prospective Payment System Rate Update; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements:
Proposed Reduction to the National, Standardized 60-Day Episode Payment Rate To Account for Nominal Case-Mix Growth
- CMS should implement program integrity measures to address provider-specific up-coding as an alternative to across-the-board case mix creep adjustments.
- CMS should not impose adjustments to payments until the completion of rate rebasing in 2017.
Proposed Home Health Value Based Purchasing: Performance Assessment and Payment Periods
- CMS have systems in place to verify the accuracy of the quarterly reports, and reconcile those reports that contain inaccurate information.
- Utilize a system similar to the Hospice Information set, where data is submitted directly to the CMS’s Quality Improvement and Evaluation System QIES ASAP system
Proposed Home Health Value Based Purchasing: Proposed Measures
- Make adjustments to the measure set based on lessons learned during the course of the model.
- Continually test the measure set to verify that the measures are risk adjusted for socioeconomic factors that could impact outcomes, and adjustments to the measures would be made during the course of the model.
- Reduce the number of quality measures being used to determine payment.
- Measures need to be valid in the setting tested. We don’t want measures that are valid in a nursing home setting to be automatically applied to home health. There are more factors that impact care outcomes in home health.
- Mainly focus on outcome measures that reflect the actual care provided for the patient including measures that address if the home health agency stabilized the patient’s condition
Proposed Home Health Value Based Purchasing: Advance Care Planning Measure
LeadingAge recommends this measure not be used.
Proposed Home Health Value Based Purchasing: Adverse Event for Improper Medication Administration and/or Side Effects
LeadingAge recommends not using a measure for Adverse Event for Improper Medication Administration and/or Side Effects.
Proposed Home Health Value Based Purchasing: Influenza Vaccination Coverage for Home Health Care Personnel
- CMS should only apply this measure to staff that have direct contact with the patient.
- CMS conduct an analysis of the cost of implementing this new measure.
Proposed Home Health Value Based Purchasing: Herpes Zoster Vaccine (Shingles Vaccine) for Patients
LeadingAge recommends that CMS not include Herpes Zoster Vaccine (Shingles Vaccine) for patients, as a measure to be tracked under Medicare Home Health.
Proposed Home Health Value Based Purchasing: The Payment Adjustment Methodology
LeadingAge suggests that CMS begin with a payment adjustment factor for CY 2018 of 1.50%, which is comparable to the Hospital VBP program.
Starting at a lower payment adjustment factor would reduce the possibility of the unintended negative consequences that could occur from implementing the HH VBP program.
A 5% reduction in payment could have a negative impact on smaller home health agencies, home health agencies in rural and frontier areas that may not have access to the resources to analyze data and make improvements in their services to generate better scores.
We also recommend annual evaluations be completed by an independent research group, and that CMS not increase the scheduled adjustment to payment in 2021, if the evaluations show that there has been a decrease in access to home health services for Medicare beneficiaries.
Proposed Home Health Value Based Purchasing: Evaluation
LeadingAge recommends annual independent evaluations of Home Health Value based Purchasing that includes state specific data on changes in home health quality outcomes, changes in home health utilization and access to home health for patients with specific diagnosis and functional status.
The evaluation should also include the impact of home health value based purchasing on home health services in rural areas of states in the pilot.
HH QRP Quality Measures and Measures Under Consideration for Future Years
LeadingAge recommends CMS only use measures:
- After they have been tested and proven to have meaningful risk adjustment (acuity of patient, environment and social supports and setting of care).
- After they have been tested in the home setting and proven to be person-centered (reflect the patient’s goals) and are realistic for their disease state
LeadingAge supports value based purchasing especially since nonprofit home health providers have incorporated quality initiatives as a critical part of their operations.
We want to see a value based program that truly reflects care outcomes for the population being served under the Medicare home health benefit.
We appreciate the home health members that shared their observations and recommendations on the proposed rule with us.