On January 18th, CMS presented a slideshow through their Medicare Learnings Network on a possible new payment refinement to home health care reimbursement called the Home Health Groupings Model (HHGM). This was the second call in six months where Abt Associates, CMS’ contractor, shared the HHGM background in addition to the 178 page technical report they issued in November 2016. This sure seems to be picking up speed.
What is HHGM? It is essentially a refinement of the Home Health Resource Groups (HHRG) reimbursement methodology that eliminates using therapy visits as a key factor in determining the resource use (think case-mix weight) in home health. The model is based on 128 payment groups defined by 5 categories:
- Timing – new 30 day periods where the first 30 days is “early”, all other 30 day periods are considered “late”
- Referral Source – community or institutional
- Clinical Groupings – one of 6 groups based on primary diagnosis
- Functional Level – high, medium or low based on 8 OASIS items
- Comorbidity – “yes” or “no” answers based on secondary diagnosis
Although this is a significant difference in how HHRGs are now calculated, Abt did note that the existing OASIS and claims data would provide all the necessary variables in calculating the new groups. The good news is that no new OASIS assessments would be required. They also shared that this new model will improve the reimbursement for agencies serving beneficiaries who are dual eligible, have poorly controlled clinical conditions, and those with high levels of severity of illness (wounds, parenteral nutrition, etc.).
One important change will be the 30 day payment groups that can now be billed after the “early” episode is completed. Cash flow could be severely impacted as it was suggested that requests for anticipated payments (RAPS) may go away now that agencies can bill every 30 days. Without RAPS, cash flow would be impacted as it will be difficult for agencies to request a final bill in 30 days given the inherent delays in obtaining timely signed physician orders and face-to-face (F2F) documentation.
The HHGM was introduced in the CY 2017 Home Health Prospective Payment System Rate proposed rule last July, and again in the final rule in November. This took place after stakeholder outreach from a Clinical Workgroup (June 2014, Oct 2015) and a Technical Workgroup (Jan 2015). Since 2011 MedPAC has also commented that the HHRG model needed refinement. They note that too much emphasis is placed on therapy visits where the prospective payment model still acts like a fee-for-service (FFS) payment.
Abt did emphasize that there was no target date yet for implementation of the model and that there was still some work to be done. Given all the communication and activities to-date and the suggested improvements to the existing HHRG model, it doesn’t appear there is anything to stop CMS’ momentum to move in this direction soon.
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