Home Health Star Rating Updates: Preparing for Home Health Value-Based Purchasing

The October 2022 quarterly refresh for the Home Health Quality Reporting Program is now available. For this update, we saw both the average Quality of Patient Care and HHCAHPS Star Ratings remain consistent with July ratings. In addition, there was no change to the hospitalization and emergency department use scores.

BerryDunn offers complimentary Home Health Quality Charts with national and state averages as well as the results for the top 10% and 20% to help agencies identify specific areas of concern. You can access the results in our complimentary portal.

PODIUM | Help Home Health Providers with Inflation

Colorado Politics | By Don Knox

Home care agencies serving Medicaid patients are in a catch-22 with the current inflation rate and the higher cost of everything these days. On one hand, the critical services these agencies provide in Colorado communities have never been more needed. The most vulnerable among us are often hit the hardest when times get tough, and the invaluable services provided by home care workers help to keep Colorado’s Medicaid patients safe and healthy in their homes. On the other hand, the cost of providing these services has also never been higher, while the reimbursement for these services has not yet been adjusted by the Colorado Legislature to keep pace.

If home care agencies can’t cover the multitude of costs that go into delivering safe and effective Medicaid care under current reimbursement rates, how will they be able to continue serving patients? The reality is, they may not be able to. Agencies are quite literally being squeezed out of Medicaid — with the fate of patients and caregivers alike hanging in the balance.

The solution? The state needs to ensure reimbursement rates for Medicaid providers keep up with inflation and the rising costs of expenses that are inherent in delivering Medicaid services in the home — including the need for these agencies to provide competitive compensation for hard-working caregivers. These workers are also struggling with the high cost of living.

It isn't only the state’s Medicaid population that stands to lose. Taxpayers also have a lot at stake. Extensive research demonstrates the lower costs for at-home services provided through Colorado Medicaid programs such as Home and Community-Based Services waivers. According to the U.S. Department of Health and Human Services, average monthly spending for Medicaid clients under these waivers was $485 per month, compared with an average monthly spending per Medicaid-covered nursing home resident of $2.4K. That's a staggering difference. According to HHS, by investing in home and community-based services, Colorado is among the states that likely has avoided building nursing home beds that otherwise would have been built. If provider agencies are squeezed out of providing these cost-saving services, Colorado taxpayers will be the ones forced to foot the bill.

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Dissecting the 2023 Home Health Final Rule: Several Articles to Help

The following articles help to bring additional perspective to the home health final rule and bring attention to things to look out for besides the pending rate cuts. Also see the downloadable resources included at the end of this section. 

NAHC President: CMS Was Tactical, Strategic In How Final Rule Was Announced
Home Health Care News | By Patrick Filbin

By walking back severe cuts initially proposed in the home health payment rule, the U.S. Centers for Medicare & Medicaid Services (CMS) was strategically trying to create positive feelings about the final rule in order to have an upper hand down the line.

That is the assessment made by William A. Dombi, president of the National Association for Home Care & Hospice (NAHC), less than a week removed the final rule’s publishing.

“It’s important to understand some of the politics of what happened in this final rule,” Dombi said during a NAHC webinar Friday. “CMS went with a headline saying they were cutting over $800 million — in one year alone — from home health care spending to a headline that now says they’re increasing spending by $125 billion. That was a strategic, tactical move by CMS to put out a positive headline.”

That messaging, Dombi said, has helped CMS initially convince Congress that lawmakers may not have to make any additional changes.

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From HHVBP to LUPAs: Additional Takeaways From The 2023 Home Health Final Rule
Home Health Care News | By Patrick Filbin

Following the Centers for Medicare & Medicaid Services’ (CMS) release of the final payment rule, it is critical for each home health agency to figure out its own financial standing and strategic plan for 2023. 

In addition, agencies should be finding key areas for improvement and educating clinicians on the recalibrated case-mix weights and Low-Utilization Payment Adjustment (LUPA) thresholds.

Those suggestions came during a Thursday webinar with experts with the home health consulting firm SimiTree.

“Each agency is going to be different in terms of what the financial impacts are going to be,” Nick Seabrook, managing principal at SimiTree, said. “The LUPA threshold going down is going to be a pretty significant change to agencies and that could move the needle pretty significantly from a revenue standpoint as well. It’s important to know what the impact of this is for your agency.”

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What Home Health Providers May Change Due To Final Rule
Home Health Care News | By Andrew Donlan

Now that the final payment rule for the home health care industry is officially out, providers and advocates will take the long-awaited next step.

For advocates, that will mean continuing legislation efforts. Although the final rule includes a 0.7% aggregate payment bump for home health agencies, behavioral adjustment cuts are still being implemented. That’s a phased-in approach that the Centers for Medicare & Medicaid Services (CMS) would like to continue in coming years. 

“We now turn to Congress to correct what CMS has done and prevent the impending harm to the 3.2 million highly vulnerable home health patients that depend on this essential Medicare benefit annually,” National Association for Home Care & Hospice (NAHC) President William A. Dombi said in a statement shared with Home Health Care News Monday. “Even with the limited phase-in of the rate cut, with significantly rising costs for staff, transportation, and more, home health agencies across the country cannot withstand the impact of rate cuts.”...

...There will still be margin pressures due to the final rule – and final rules for future years – if the Preserving Access to Home Health Act does not gain any more traction in Washington, D.C. That piece of legislation would curb any cuts to home health reimbursement until 2026.

And if the margins are not there, less investment in other service lines is almost a certainty. But what may actually tick up is investment in technology in order to increase efficiency in certain areas.

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RESOURCES

HH Final Rule 7.85% Rate Cut: Advocacy 1-Pager

HH Final Rule Federal Health Policy Strategies Analysis

CAP Reporting for the 2022 CAP Year

The Health Group 

The 2022 CAP Year ended on September 30, 2022.  All hospices must file their self-determined CAP (“CAP Report”) for the 2022 CAP Year between January 1, 2023, and February 28, 2023.  Tips relating to CAP reporting include the following:

• Secure beneficiary counts and payments for the 2022 CAP Year as soon as possible on or after January 1, 2023.  This will ensure that the hospice reports the lowest CAP liability, if one exists, at the time of self-filing.

• Even though the hospice secures data at or near January 1, 2023, the CAP Report does not need to be filed until February 28, 2023.

• If the CAP Report indicates a liability due to the Medicare program, early preparation of the CAP Report will better prepare the hospice for any liability which needs to be paid based on the self-filing.

• If the hospice will be reporting a CAP liability and needs to secure an Extended Repayment Schedule (“ERS”) to repay the liability, the hospice will need to begin accumulating the information needed to apply for an ERS.  This includes up-to-date financial information through December 31, 2022.

• Terminated providers should file their final CAP Report on or before February 28, 2023, if they terminated Medicare participation and the termination has been processed.

• Visit the respective website of the servicing Medicare Administrative Contractor (“MAC”) regarding calculated overpayments and making repayments.  The instructions issued by the MACs are not consistent.

• Remember, the MAC will recalculate the CAP liability or potential CAP liability annually for at least three (3) years.  Even if you do not report a liability at the time of self-filing, the hospice may experience a liability for the 2022 CAP Year later.  If you will be self-reporting a CAP liability, or if the margin between the calculated CAP and Medicare payments for services rendered during the CAP Year is insignificant, the hospice may need to make estimates of the ultimate CAP liability for financial statement, PRF reporting, or other purposes.

• Retain a copy of all submissions and correspondence between the hospice and the MAC relating to the CAP.