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Home Health Final Rule Release and How to Prepare for VBP

CMS published the final rule for CY2022 making official the nationwide expansion of the HHVBP Model. The HHVBP Model is one of four Innovation Center models that have met the requirements to be expanded in duration and scope since 2010. Given this expansion, CMS is also ending the HHVBP Model for participants in the original model’s nine states. The first performance year of the expanded HHVBP Model will be CY 2023, with quality performance data from that year used to calculate payment adjustments under the expanded Model in CY 2025. Throughout 2022, CMS will provide technical assistance to HHAs to ensure they understand how performance will be assessed as finalized in this rule. To take an in-depth look at VBP click here: What is Value Based Purchasing?

The final rule also updates Medicare payment rates and the wage index for Home Health Agencies (HHAs). CMS estimates that Medicare payments to HHAs in CY 2022 would increase in the aggregate by $570 million or 3.2%.

Other notable highlights of the complete final rule include:

  • Home Health Conditions of Participation updates
  • Provisions to allow Occupation Therapists (OTs) to conduct initial and comprehensive assessments Click here to learn more on Therapy SOCs Therapy SOC
  • Updates to the Home Infusion Therapy Benefit
  • Home Health Quality Reporting Program Updates
  • Recalibration to parts of the Patient-Driven Groupings Model (PDGM).

Now is the time to start preparing for Home Health Value Based Purchasing (HH-VBP). There are some critical steps that your agency can take now in order to maximize success under the HHVBP model. The list below includes questions that you should consider and develop a HHVBP action plan, which can be intertwined with your current QAPI plan.

Questions Worth Exploring With Your Agency’s Team

  • Are we familiar with the HHVBP Model measures and the source data that is currently available through CASPER, Home Health Compare, and the Home Health CAHPS Survey?
  • Have we reviewed our agency’s current performance in these processes, outcomes, and HHCAHPS Survey data? How does our current data compare to our baseline year data?
  • What education can we provide our clinicians for OASIS measures to ensure accuracy in the data? Are measures being reported accurately at both SOC and DC?
  • Do we have a plan for improving the HH-VBP measures into our agency’s quarterly QAPI Program? Do we have QAPI goals that are objective and measurable so you can track progress over time?
  • How can we stay informed of the HH-VBP requirements?
  • What is the best way to systematically integrate data into our current workflows?
  • How will management staff develop their own action plans for items needing attention?
  • Could we have our therapy team “own” the patient functional improvements metrics and scores?
  • How can we ensure our clinical documentation is both facilitating and supportive of our OASIS scores?
  • What does our timely submission of documentation look like and how can we optimize it?
  • How are nurses, therapy, and the QA team communicating and collaborating?
  • How can we share data and the ‘why’ with clinicians, management teams, and back office?
  • What do our education efforts to our team look like? How will we provide continuous feedback for quality improvement?
  • What is our current hospitalization rate? What measures are we taking to minimize rehospitalizations? (medication reconciliation, tuck in calls, front-loading visits, call us first)
  • Do we have care pathways developed to provide guidance to clinicians on best practices for clinical delivery and maximization of clinical outcomes?
  • Do we have proactive orders to care for our patients in the event of an exacerbation?
  • How are we working upstream and downstream to provide warm handoffs and transition our patients safely between care settings?
  • Are we working with our clinical teams to match our clinical resources to patient acuity?
  • Are we involved with discharge planners and physicians in determining the best next level of care?
  • What resources can our Social Worker provide to help minimize hospitalizations and improve patient satisfaction and outcomes?
  • How can we enhance our patient experience by leveraging technology?
  • What are we doing to implement strategies to increase both the return rate and scores with our HHCAHPS surveys?
  • How can we use our data to gain additional partnerships and increase market density?

As you work through this list of questions and identify your pain points and greatest opportunities, consider reaching out to HealthPRO Heritage at Home at homehealth@healthpro-heritage.com for additional support. We are here to answer questions you may have and provide support to ensure your success in 2022 and beyond.

Tags: Home Health, Home Health Agency, #homehealth