CMS issued the Proposed CY 2017 Home Health PPS Rule in the Federal Register on July 5th. We have been waiting for over eight months to see how four of the 21 HHVBP measures were going to be implemented and we finally have our answer. They’re not. Since November, agencies have been inquiring how these measures listed below would be calculated since there were no definitions shared in the CY 2016 Home Health Final Rule.
- (1) Care Management: Types and Sources of Assistance;
- (2) Prior Functioning ADL/IADL;
- (3) Influenza Vaccine Data Collection Period; and
- (4) Reason Pneumococcal Vaccine Not Received
NAHC and VNAA had met with CMMI back in March regarding these 4 measures and were told to wait for the next rule making. And we now know; they will not be used as one of the measures to calculate the Total Performance Score (TPS) for VBP.
Another notable VBP proposed change addressed the small and large volume cohort definitions. First, CMS changed the minimum requirement to eight HHAs in a size cohort. This will limit the number of states with small cohorts to four (Florida, Oklahoma, Iowa and Arizona). Secondly, size will not be used to calculate the base year Achievement Threshold and Benchmarks in each state. CMS noted the larger variances when calculating Thresholds and Benchmarks among small volume cohorts. Cohorts will be used only for purposes of calculating the linear exchange function (LEF) to translate a competing HHA's TPS into a value-based payment adjustment.
The Proposed Rule also changed some of the time frames for submitting New Measure data to 15 days (up from 7 calendar days) after each reporting period. At the same time they decreased the recalculation time frame request period for the Interim Performance Reports and the Annual TPS and Payment Reports from 30 days down to 15.
So how are agencies performing in the first 6 months of this first VBP performance year? For this review, we looked at three OASIS outcome measures from the SHP national database. We compared the agency median scores for the 6 month period January – June 2016 to the previous six months.
| State | Q3/4 2014 | Q1/2 2015 | Q3/4 2015 | Q1/2 2016 | Chg. Q3/4 2014 to Q1/2 2015 | Chg. Q3/4 2015 to Q1/2 2016 | |
|---|---|---|---|---|---|---|---|
| Improvement in Ambulation | AZ | 63.5% | 63.5% | 64.5% | 66.0% | 0.0% | 1.5% |
| FL | 66.0% | 68.6% | 70.1% | 72.0% | 2.6% | 1.9% | |
| IA | 65.7% | 67.4% | 69.1% | 70.4% | 1.7% | 1.3% | |
| MA | 65.8% | 67.9% | 68.2% | 68.4% | 2.1% | 0.2% | |
| MD | 65.0% | 66.7% | 69.5% | 72.3% | 1.7% | 2.8% | |
| NC | 62.6% | 64.3% | 67.4% | 69.3% | 1.7% | 1.9% | |
| NE | 61.5% | 63.9% | 66.1% | 69.1% | 2.5% | 3.0% | |
| TN | 65.1% | 67.4% | 69.4% | 73.2% | 2.3% | 3.8% | |
| WA | 57.7% | 59.4% | 63.8% | 64.8% | 1.7% | 1.1% | |
| Improvement in Bathing | AZ | 73.1% | 72.3% | 73.1% | 75.6% | -0.8% | 2.6% |
| FL | 74.7% | 75.4% | 77.2% | 79.4% | 0.6% | 2.2% | |
| IA | 73.3% | 72.1% | 72.8% | 76.8% | -1.2% | 4.0% | |
| MA | 67.0% | 69.6% | 69.8% | 74.0% | 2.6% | 4.2% | |
| MD | 70.0% | 71.4% | 74.1% | 78.4% | 1.5% | 4.3% | |
| NC | 63.4% | 66.1% | 69.1% | 72.8% | 2.7% | 3.6% | |
| NE | 70.3% | 70.1% | 74.5% | 78.3% | -0.3% | 3.8% | |
| TN | 70.9% | 72.3% | 76.7% | 79.5% | 1.4% | 2.8% | |
| WA | 64.9% | 66.7% | 69.5% | 72.4% | 1.8% | 2.8% | |
| Improvement in Bed Transferring | AZ | 60.1% | 60.3% | 62.9% | 65.1% | 0.2% | 2.3% |
| FL | 61.7% | 64.0% | 65.2% | 67.3% | 2.2% | 2.1% | |
| IA | 63.3% | 63.3% | 64.7% | 68.6% | 0.1% | 3.9% | |
| MA | 59.3% | 62.6% | 65.2% | 66.6% | 3.2% | 1.4% | |
| MD | 61.2% | 63.6% | 65.1% | 68.1% | 2.4% | 2.9% | |
| NC | 58.8% | 60.3% | 63.0% | 66.4% | 1.5% | 3.3% | |
| NE | 65.0% | 65.7% | 67.0% | 70.6% | 0.6% | 3.5% | |
| TN | 60.1% | 61.3% | 64.7% | 68.3% | 1.3% | 3.5% | |
| WA | 55.4% | 55.7% | 61.1% | 65.1% | 0.3% | 3.9% |
The results were as expected. In all cases the median scores have improved in the first six months of FY 2016. The average increase was 2.8%. This compares to the prior year, looking at the same two time periods, where the increases averaged 1.3%. This is less than half of the increase from the first six months under VBP. Clearly, agencies are stepping up their efforts in improving their VBP measure scores.
Agencies in each of the 9 states are competing against each other. Agencies not only have to improve their outcomes to generate higher TPS scores, but have to improve better than their competition to increase the opportunity for higher bonus payments under VBP. Benchmarking your scores to determine your relative position in your state will be very important in tracking your progress.
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