CMS Announces Proposed Home Health PPS Update for 2016; Massachusetts Included in Value-Based Pilot

Massachusetts is one of nine states randomly assigned to pilot the Home Health Value-Based Purchasing (VBP) model, which is included in the calendar year 2016 Medicare Home Health PPS Rule released by CMS.

VBP will test whether incentives for better care can improve outcomes in the delivery of home health services.  The model will apply a payment reduction or increase to current Medicare-certified home health agency payments, depending on quality performance, for ALL agencies delivering services within the nine selected states.  Payment adjustments will be applied on an annual basis, beginning at five percent and increasing to eight percent in later years of the initiative.

According to CMS, the model is designed so there is no selection bias, participant states are representative of home health agencies nationally, and there is sufficient participation to generate meaningful results among all Medicare-certified home health agencies nationally.

The proposed rule implements the third year of the four year phase-in of the rebasing adjustments to the HH PPS required by the Affordable Care Act.  The CY 2016 downward adjustment to the national standard episode rate is $80.95.  CMS also proposes to recalibrate the HH PPS case-mix weights for CY 2016, which would be the second year of recalibration and identical to CY 2015.

In addition, the proposed rule includes a decrease to the national, standardized 60-day episode payment amount by 1.72 percent in each of CY 2016 and CY 2017 to account for nominal case-mix coding intensity growth unrelated to changes in patient acuity between CY 2012 and CY 2014.  CMS will also be updating the HH PPS payment rates by the home health payment update percentage, 2.3 percent in CY 2016.

For the Home Health Quality Reporting Program, in keeping with the requirements of the Improving Medicare Post-Acute Care Transformation Act of 2014 (the IMPACT Act), CMS is proposing one standardized cross-setting measure for CY 2016 under the skin integrity and changes to skin integrity domain.  Measures for the IMPACT Act’s other domains will be addressed through future rule-making, although CMS is seeking feedback on four future, cross-setting measure constructs to potentially meet requirements of the IMPACT Act.

In order for home health agencies to avoid a two percent reduction in their annual HH payment update percentage, the rule further proposes to require all home health agencies to submit both admission and discharge OASIS assessments for a minimum of 70 percent of all patients with episodes of care occurring during the reporting period starting July 1, 2015.  CMS proposes to incrementally increase this compliance threshold by ten percent in each of the subsequent periods (July 1, 2016 and July 1, 2017) to reach 90 percent.

CMS has prepared a fact sheet about the proposed rule and a press release about the Home Health Value-Based Purchasing model.  The proposed rule will be officially published in the Federal Register on July 10, 2015. CMS will accept comments on the proposed rule, including comments about the Home Health Value-Based Purchasing model, until September 4, 2015.

The Alliance will closely examine the Value-Based Purchasing proposal — as well as all other aspects of the proposed rule — and will present a briefing for members within the next weeks.

We will work with the state associations in the other states chosen for the pilot to advocate for any needed changes to the program to protect agency cash flow and operational integrity.  We will also develop educational sessions for our members over the next months.  Stay tuned!

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