HCAF Conference Endnotes and the Move to Meet Benchmarks

Homecare Association of Florida wrapped up its 28th Annual Conference and Trade Show.

Kyle Simon, director of Government Affairs and Communications, said the number of sessions, speakers and attendees exceeded past years. More than 700 Florida homecare professionals attended for a program consisting of 74 workshops and sessions over five days. Some 83 national and state homecare experts presented. The two-day tradeshow featured 118 vendors.

“This is a reflection of the critical need for education amid the ever-changing landscape of the industry—more regulations, demonstrations and uncertainty, and homecare professionals want to acquire the information and skills to stay compliant and grow their businesses. With that reality in mind, the theme ‘Reflect, Reset and Renew’ was especially fitting,” Simon said.

Developments continue to add new wrinkles in the ways companies can do business now and in the not-so-distant future. In development is a refined payment methodology by 2019. CMS is soliciting comments.

CMS-1672-P was published July 28, 2017, and proposes updating the Medicare Home Health Prospective Payment System (HH PPS) rates and wage index for the calendar year 2018. The proposed policies included in the rule would result in a 0.4 percent decrease, or $80 million, in payments to HHAs in CY 2018, according to CMS. The proposed decrease reflects the effects of a 1 percent home health payment update percentage ($190 million increase); a -0.97 percent adjustment to the national, standardized 60-day episode payment rate to account for nominal case-mix growth for an impact of -0.9 percent ($170 million decrease); and the sunset of the rural add-on provision ($100 million decrease).

For CY 2019 payments, CMS proposes to implement an alternative case-mix adjustment methodology, the Home Health Groupings Model (HHGM). The HHGM would use 30-day periods, rather than 60 days episodes, in recognition of higher utilization during the first 30 days.

Section 411(c) of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires the market basket percentage increase to be 1 percent for home health payments for CY 2018. Home health payments will be increased by 1 percent for HHAs that submit the required quality data for the Home Health Quality Reporting Program (and a 1 percent reduction for HHAs that don’t submit quality data).

“Reimbursement in all sectors of health care is moving from paying for services rendered to payment for meeting quality benchmarks,” comments Lucy Carter, member and practice leader of the healthcare industry team at KraftCPAs PLLC. “Developing and adopting the reporting needed to meet the quality guidelines going forward will be a major determinate of success.”

Factors forward, according to CMS, would rely more heavily on clinical characteristics and other patient information (e.g., principal diagnosis, functional level, comorbid conditions, referral source and timing) to place patients into meaningful payment categories.

For the HH Quality Reporting Program (QRP), CMS is proposing to adopt for the CY 2020 payment determination three measures to meet the requirements of the IMPACT Act and new standardized data elements. These three measures are assessment-based and are calculated using Outcome and Assessment Information Set (OASIS) data. They focus on pressure ulcer/injury, falls with major injury (NQF #0674), and functional assessment at discharge and a care plan that addresses function (NQF #2631).

To reduce provider burden, CMS is proposing to remove or modify current OASIS items. CMS is also proposing processes for requesting reconsideration of determinations regarding compliance with pay-for-reporting requirements, as well as a process for providing exceptions to these policies and extensions to reporting timeframes. Lastly, CMS is also proposing changes to the Home Health Value-Based Purchasing (HHVBP) Model.

The recent announcement of the HH PPS proposed rule ignited concern from the Partnership for Quality Home Healthcare (PQHH). The PQHH circulated a press release urging the Centers for Medicare & Medicaid Services (CMS) to work collaboratively with the home health provider community to address what it calls “significant flaws” in the Home Health Groupings Model (HHGM) as proposed by the recent HHPPS proposed rule and proposes to implement a payment reform approach that “dramatically alters” Medicare payment for skilled home health services.

More to come: The comment period for CMS-1672-P ends at 5 pm EST, September 25, 2017. Details can be found on the CMS website.

In other announcements, the National Association for Home Care & Hospice (NAHC) points to the Office of Inspector General (OIG) announcing new areas of inquiry in home health and hospice. OIG has issued its Work Plan, which outlines many of the investigations the OIG has in process. Monthly updates and new inquiries can be found on the OIG website.