Final Rule Gives Home Health Agencies Breathing Room for HHVBP, Medicare Sequestration


Now that the ultimate residence well being cost rule for 2022 has been floating round for a couple of days, business insiders have had time to choose it aside and 0 in on key adjustments, together with the nationwide growth of the House Well being Worth-Primarily based Buying (HHVBP) Mannequin.

A major distinction between the finalized growth of HHVBP and the unique proposal from the U.S. Facilities for Medicare & Medicaid Providers (CMS) is that the mannequin will now start Jan. 1, 2023.

This delay will give residence well being suppliers throughout the U.S. extra room to breathe, Valerie Cornett, chief of technique and innovation at MAC Legacy, advised House Well being Care Information.

“This can permit companies that weren’t a part of the earlier demonstration to turn into extra operationally ready,” she stated. “It is going to permit companies to do some monetary evaluation and get extra OASIS coaching for accuracy amongst their employees. It is going to additionally give them time to turn into extra fluent with the standard measures now that there’s extra exhausting traces round it.”

MAC Legacy is a Denton, Texas-based residence well being and hospice coding and consulting firm.

One other benefit for suppliers is that whereas HHVBP’s begin date has been pushed again, the vast majority of its provisions stay unchanged from the proposal stage.

“We’ve had the proposed rule because the summer season and had a while to get accustomed to it,” Aaron Little, managing director at BKD, advised HHCN. “Realizing that there have been no vital adjustments from what was proposed to us and finalized, when it comes to the construction of HHVBP, is sweet. It simply offers much more time to soak up and take into consideration how that is going to doubtlessly impression companies.”

BKD is a Springfield, Missouri-based accounting companies agency that gives billing and income cycle outsourcing companies. BKD and MAC Legacy introduced a strategic collaboration on the finish of October to offer their purchasers entry to extra sources.

Broadly, HHVBP has many supporters among the many residence well being business attributable to its potential to spice up high quality scores and Medicare financial savings.

HHVBP is a Medicare demonstration that hyperlinks reimbursement to high quality of care. Beneath the mannequin, residence well being suppliers are paid based mostly on how nicely they preserve their sufferers wholesome and out of the hospital. Since 2016, Medicare-certified residence well being companies in Massachusetts, Maryland, North Carolina, Florida, Washington, Arizona, Iowa, Nebraska and Tennessee have participated within the demo.

“One of many good issues about HHVBP is that it wasn’t set as much as take new efficiency measures that companies aren’t aware of or accustomed to,” Little stated. “In case you’re striving towards high quality, that must also translate nicely into your monetary outcomes. It’s tying within the data from the OASIS, the knowledge from the patient-experience surveys and hospital readmissions, which companies are already centered on managing.”

Since its 2016 implementation, the mannequin has resulted in a median 4.6% enchancment in residence well being companies’ high quality scores and a median annual financial savings of $141 million to Medicare, in accordance with CMS.

Advisable HHCN+ Exclusives

Nonetheless, some residence well being stakeholders imagine there may be nonetheless room for enchancment with regards to HHVBP.

The Nationwide Affiliation for House Care & Hospice (NAHC) has pushed for CMS to undertake a risk-sharing strategy for HHVBP, for instance.

“The danger-sharing idea will not be international to value-based buying applications,” Invoice Dombi, president of NAHC, stated throughout a Friday webinar. “We thought it match very well with a refinement and enchancment of [HHVBP]. This system in residence well being has one company competing in opposition to one other to be able to get both a bonus or penalty, however a few of the suppliers which can be beneath the imply and can be penalized truly deliver financial savings to the Medicare program.”

Dombi famous that these companies that fall “beneath common” relative to efficiency enchancment are nonetheless anticipated to contribute practically $3.4 billion in financial savings to the Medicare program over 5 years.

Apart from the growth of HHVBP, the rule establishes a 3.2% improve to the house well being Medicare charge for subsequent yr. This shakes out to be a $570 million bump.

The three.2% bump amends a 1.7% improve that was initially introduced within the proposal.

The speed improve, one of many largest for the house well being business in years, might assist offset Medicare sequestration which was initially postponed to assist suppliers all through the COVID-19 emergency.

“We expect sequestration to come back again into play in January, so it’s good to see that the rise was greater than 2%,” Little stated.

As the general public well being emergency continues, a further monetary cushion shall be an total assist to suppliers, in accordance with Cornett.

“Extra than simply the looming return of sequestration, any little bit will assist,” she stated. “Because the starting of the general public well being emergency, companies have needed to be actually inventive. Retaining sufferers and employees secure has further prices related to it. Suppliers want reduction from that.”

Cornett famous that these prices embody provides, know-how, rising salaries and turnover.

Additionally of notice, the rule finalized a recalibration to components of the Affected person-Pushed Groupings Mannequin (PDGM), although the rule basically maintains the construction of the mannequin when it comes to case-mix classes and LUPA thresholds.

“[This includes] the recalibration of all 432 case-mix weights and [the finalization] of the transition to the brand new CBSA wage index that CMS started on this present yr, however started with a 5% cap on any damaging adjustments to the wage index,” Dombi stated. “And on this case, they’ve eradicated the cap.”

One factor that hasn’t modified is PDGM’s 4.36% behavioral adjustment.

“CMS’s rationalization for not eager to do something with it’s they nonetheless don’t have a full yr of fresh knowledge from 2020,” Dombi stated. “We’ve been advocating for that 4.36% to drop, if not drop out fully, as a result of our observations … point out CMS’s behavioral adjustments that had been anticipated didn’t materialize.”

For instance, CMS anticipated LUPA quantity to go down in response to the brand new cost mannequin; as a substitute, they went up considerably, seemingly as a result of public well being emergency.

Moreover, CMS projected the habits adjustments would come with upcoding of the first analysis, which didn’t occur, in accordance with Dombi.

General, NAHC believes that the ultimate rule will usher in a level of stabilization in residence well being

“[There are] no actual massive architectural adjustments throughout the cost mannequin itself, though positively some which [have] materials impression,” Dombi stated.