The Home Health Groupings Model (HHGM)

Similar documents
HOT ISSUES FACING HOME HEALTH & HOSPICE AGENCIES. Luke James Chief Strategy Officer Encompass Home Health & Hospice

A Critique of MedPAC s Post-Acute Care Prospective Payment System Prototype

CY 2018 Home Health PPS Proposed Rule

Home Health Agency (HHA) Medicare Margins: 2007 to 2011 Issue Brief July 7, 2009

2017 Home Health PPS Rate Update

Acting Assistant Secretary for Planning and Evaluation Centers for Medicare & Medicaid Services Department of Health and Human Services

September 25, Via Regulations.gov

September 22, 2017 VIA ELECTRONIC SUBMISSION

Analysis of 340B Disproportionate Share Hospital Services to Low- Income Patients

Medicare Home Health Prospective Payment System

CY2019 Proposed Medicare Home Health Rate Rule and Much More

Dobson DaVanzo & Associates, LLC 440 Maple Avenue East, Suite 203, Vienna, VA

Medicare Home Health Prospective Payment System (HHPPS) Calendar Year (CY) 2013 Final Rule

Dobson DaVanzo & Associates, LLC 440 Maple Avenue East, Suite 203, Vienna, VA

Dobson DaVanzo & Associates, LLC Vienna, VA

Medicare Home Health Prospective Payment System Calendar Year 2015

Using the New Home Health Agency (HHA) PEPPER to Support Auditing and Monitoring Efforts

HHGM is Alive and Kicking: How Can You Prepare for What s Next?

Medicare Spending and Rehospitalization for Chronically Ill Medicare Beneficiaries: Home Health Use Compared to Other Post-Acute Care Settings

The Honorable Seema Verma Administrator Centers for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, Maryland

PROPOSED RULE: MEDICARE PROGRAM; HOME HEALTH PROSPECTIVE PAYMENT SYSTEM RATE UPDATE FOR CY 2013 SUMMARY. July 17, 2012

Medicare Home Health Prospective Payment System

Medicare Home Health Prospective Payment System

PROPOSED POLICY AND PAYMENT CHANGES FOR INPATIENT STAYS IN ACUTE-CARE HOSPITALS AND LONG-TERM CARE HOSPITALS IN FY 2014

You re In or You re Out: Determining Winners and Losers Under a Global Payment System

All Medicare Advantage Organizations (MAOs), PACE Organizations, Cost Plans, and certain Demonstrations

All Medicare Advantage Organizations (MAOs), PACE Organizations, Cost Plans, and certain Demonstrations

MEDICARE FFY 2017 PPS PROPOSED RULES OVERVIEW OHA Finance/PFS Webinar Series. May 10, 2016

Home Health Market Overview

Prepared for North Gunther Hospital Medicare ID August 06, 2012

HOME DIALYSIS REIMBURSEMENT AND POLICY. Tonya L. Saffer, MPH Senior Health Policy Director National Kidney Foundation

Programs Driving PROGRESS. in Health Policy Research. A Compendium of Abt Associates Work in Health Policy Research

Presented by. M. Aaron Little, CPA William Simione, III. Agenda Sunday, July 28, 2013, 9:00 a.m. 3:00 p.m.

January 10, Glenn M. Hackbarth, J.D Hunnell Road Bend, OR Dear Mr. Hackbarth:

Home Care and Hospice: Payment and Reimbursement Update: AHLA Institute on Medicare and Medicaid Payment Issues

Final Rule Summary. Medicare Home Health Prospective Payment System Calendar Year 2016

Preventable Readmissions Payment Strategies

Proposed Rule Summary. Medicare Home Health Prospective Payment System Program Year: CY2019

August 25, Dear Ms. Verma:

paymentbasics The IPPS payment rates are intended to cover the costs that reasonably efficient providers would incur in furnishing highquality

The President s and Other Bipartisan Proposals to Reform Medicare: Post-Acute Care (PAC) Reform. Summary

Healthcare Reimbursement Change VBP -The Future is Now

Paying for Primary Care: Is There A Better Way?

Distribution of Post-Acute Care under CJR Model of Lower Extremity Joint Replacements for MS-DRG 470

The Evolving Landscape of Healthcare Payment: Incentive Programs and ACO Model Optimization. Quality Forum August 19, 2015

HCCA South Central Regional Annual Conference November 21, 2014 Nashville, TN. Post Acute Provider Specific Sections from OIG Work Plans

CMS Proposed SNF Payment System -- Resident Classification System: Version I (RCS-1)

HOMECARE AND HOSPICE REIMBURSEMENT

Medicare Claims Processing Manual Chapter 10 - Home Health Agency Billing

Preventable Readmissions

2014 MASTER PROJECT LIST

INPATIENT REHABILITATION HOSPITALS in the United. Early Effects of the Prospective Payment System on Inpatient Rehabilitation Hospital Performance

An Initial Review of the CY Medicare Home Health Rule. CY2018 Proposed Medicare Home Health Rate Rule and Much More

Medicare Part A SNF Payment System Reform: Introduction to Resident Classification System - I

paymentbasics Defining the inpatient acute care products Medicare buys Under the IPPS, Medicare sets perdischarge

August 30, Submitted electronically

MACRA & Implications for Telemedicine. June 20, 2016

Summary of U.S. Senate Finance Committee Health Reform Bill

Hospital Rate Setting

Frequently Asked Questions (FAQ) The Harvard Pilgrim Independence Plan SM

2017 Regulatory Blueprint for Action. National Association for Home Care & Hospice 228 Seventh Street, SE Washington DC

2016 Edition. Upper Payment Limits and Medicaid Capitation Rates for Programs of All-Inclusive Care for the Elderly (PACE )

Outcomes Measurement in Long-Term Care (LTC)

Data-Driven Strategy for New Payment Models. Objectives. Common Acronyms

Decrease in Hospital Uncompensated Care in Michigan, 2015

OFFICE OF THE ASSISTANT SECRETARY OF DEFENSE HEAL TH AFFAIRS 1640 I EAST CENTRETECH PARKWAY AURORA. CO

Medicare Part A SNF Payment System Reform: Introduction to Resident Classification System - I ZIMMET HEALTHCARE 2018

Best Options for Responding to the Home Health PPS 2011 Cuts *revised handouts

Overview of the Hospice Proposed Rule

Implementing Medicaid Value-Based Purchasing Initiatives with Federally Qualified Health Centers

CMS Proposed Home Health Claims-Based Rehospitalization and Emergency Department Use Quality Measures

Medicare Value-Based Purchasing for Hospitals: A New Era in Payment

Medicare and Medicaid Programs; CY 2018 Home Health Prospective Payment System

The Financial Performance of Rural Hospitals and Implications for Elimination of the Critical Access Hospital Program

Impact of Financial and Operational Interventions Funded by the Flex Program

Critical Access Hospital Quality

Medicare Spending and Rehospitalization for Chronically Ill Medicare Beneficiaries: Home Health Use Compared to Other Post-Acute Care Settings

HHA Medicare Cost Reporting

January 2017 A GUIDE TO HOME HEALTH VALUE-BASED PURCHASING

Update to a 2012 Analysis of 340B Disproportionate Share Hospital Services Delivered to Vulnerable Patient Populations

Medicare Advantage PPO participation Termination - Practice Name (Tax ID #: <TaxID>)

Framework for Post-Acute Care: Current and Future Issues for Providers

Patient Driven Payment Model (PDPM) and the MDS: A Total Evolution of the SNF Payment Model

Health Center Strong:

Working Paper Series

Home Health Value-Based Purchasing Series: HHVBP Model 101. Wednesday, February 3, 2016

National Update : 2013 HEALTH CARE REFORM. Insurance reforms through the ACA Delivery reforms New delivery models under study

Patient-Mix Adjustment Factors for Home Health Care CAHPS Survey Results Publicly Reported on Home Health Compare in July 2017

time to replace adjusted discharges

2017/2018. KPN Health, Inc. Quality Payment Program Solutions Guide. KPN Health, Inc. A CMS Qualified Clinical Data Registry (QCDR) KPN Health, Inc.

Hospital Strength INDEX Methodology

ALTERNATIVES TO THE OUTPATIENT PROSPECTIVE PAYMENT SYSTEM: ASSESSING

Medicare, Managed Care & Emerging Trends

Hospital Inpatient Quality Reporting (IQR) Program

CMS Proposed Payment Rule FY Cheryl Phillips, MD Evvie Munley

The Shift is ON! Goodbye PPS, Hello RCS

HCBS Waiver Expansion and Medicaid Nursing Home Spending: Implications

Executive Summary. This Project

American Health Lawyers Association Institute on Medicare and Medicaid Payment Issues. History of the Physician Fee Schedule

Medicare P4P -- Medicare Quality Reporting, Incentive and Penalty Programs

Transcription:

The Home Health Groupings Model (HHGM) September 5, 017 PRESENTED BY: Al Dobson, Ph.D. PREPARED BY: Al Dobson, Ph.D., Alex Hartzman, M.P.A, M.P.H., Kimberly Rhodes, M.A., Sarmistha Pal, Ph.D., Sung Kim, Steve Heath, M.P.A, Joan DaVanzo, Ph.D., M.S.W. Dobson DaVanzo & Associates, LLC Vienna, VA 703.60.1760 www.dobsondavanzo.com 017 Dobson DaVanzo & Associates, LLC. All Rights Reserved.

Introduction and Presentation Overview Introduction Dobson DaVanzo & Associates was commissioned in early 017 to replicate the HHGM patient grouper and model payment impacts Presentation Overview HHGM s Core Elements Historical Context Dobson DaVanzo s HHGM Replication Project Results and Key Findings Dobson DaVanzo s Analysis of the HHGM as Outlined in the Proposed Rule Points to Consider 017 Dobson DaVanzo & Associates, LLC. All Rights Reserved.

HHGM s Core Elements The Home Health Groupings Model (HHGM) is a proposed replacement to the Home Health Prospective Payment System (HH PPS) case-mix system Some of the key motivations for the HHGM were to align payments more closely to patient needs and to protect access to care for vulnerable populations The HHGM would fundamentally change how home health care providers are paid and, in turn, how they deliver care. If implemented, HHGM would: No longer directly reimburse for the number of therapy visits Base reimbursement directly on patient and case characteristics These characteristics (admission source and episode timing, clinical grouping, functional level, and the presence of comorbidities) comprise the episode s case-mix weight, which is incorporated into the payment model Base Rate x Case-Mix Weight x Other Adjustments = Episode Payment Include Nonroutine Supply (NRS) costs in the base rate Shorten home health episodes from 60 days to 30 days This affects both high-cost outlier payments and low-utilization payment adjustments 017 Dobson DaVanzo & Associates, LLC. All Rights Reserved. 3

Historically, when Changes of this Magnitude were Implemented, the Field Experienced Extreme Financial Distress In the past, changes of a similar scale have created unintended effects among agencies and beneficiaries System changes in the late 1990s resulted in large-scale impacts on the industry: Agency impacts: There was a net 15% reduction in the number of Medicare Home Health Agencies 1 Beneficiary impacts: Home health utilization dropped by 9%, from 104 home health users per 1,000 in 1996 to 7 users per 1,000 in 1999 System impacts: Program payments were reduced from $16.8 billion in 1996 to $7.9 billion in 1999, and the industry had not fully recovered as of 007 3 1 Note: The actual closure rate was 6%; the entry of new agencies provided a level of offset. Source: Agency Closings and Changes in Medicare Home Health Use, 1996-1999. Page 7. U.S. Department of Health and Human Services Assistant Secretary for Planning and Evaluation Office of Disability, Aging and Long-Term Care Policy. July 003. https://aspe.hhs.gov/system/files/pdf/74761/closings.pdf. Note: Average county-level rate of decline in HHA utilization. Source: Ibid. Page 6. 3 Note: Program payments were $15.6 billion in 007. Source: Health Care Financing Review 008 Statistical Supplement. Table 7.1, Trends in Persons Served, Visits, Total Charges, Visit Charges, and Program Payments for Medicare Home Health Agency Services, by Year of Service: Selected Calendar Years 1974-007. Centers for Medicare and Medicaid Services. https://www.cms.gov/research-statistics-data-and-systems/statistics-trends-and-reports/medicaremedicaidstatsupp/downloads/008_section7.pdf#table%07.1. 017 Dobson DaVanzo & Associates, LLC. All Rights Reserved. 4

Dobson DaVanzo s HHGM Replication Project To replicate the HHGM patient grouper and model payment impacts, we closely followed the Abt Associates Technical Report 1 and used 013 data to: Construct a claims-level database, linking home health claims to OASIS assessments Build the HHGM patient grouper to place individuals into HHGM case-mix groups Assign payments for simulated HHGM 30-day episodes and simulated current law payments under 30-day episodes Build impact (predictive) ratios by dividing 30-day simulated HHGM payments by 30-day simulated current law payments at the episode level Note that impact ratios in the Abt technical report, and in Dobson DaVanzo s replication of the model describe the effects of a presumed budget neutral system Compare our impact ratios to Abt s on 80+ variables Produce impact analyses for agency-level revenues (assuming overall budget neutrality) for Fee-for-Service and ACO-attributed beneficiaries Assess HHGM s effects on agency margins 1 Overview of the Home Health Groupings Model. November 18, 016. Abt Associates. https://downloads.cms.gov/files/hhgm%0technical%0report%010516%0sxf.pdf. CMS Data Use Agreement Number 868. 017 Dobson DaVanzo & Associates, LLC. All Rights Reserved. 5

Dobson DaVanzo s HHGM Replication Results We were able to accurately replicate Abt Associates 013 HHGM model Dobson DaVanzo Replication 1 Mean Impact Ratio 1.09 1.08 (across the 84 analytic variables) Average current law 30-day episode payment $1549 $1519 Average HHGM 30-day $1549 $1519 episode payment Abt Associates Technical Report Dobson DaVanzo s mean impact ratio was.001 from Abt s Dobson DaVanzo s average episode payment calculation is $30 from Abt s; 79% of our modeled impact ratios were within +.5% of Abt s 1 CMS Data Use Agreement Number 868. Revenue neutrality to included cases implied; the system as modeled does not account for lost revenues allocated within removed or missing 30-day cases. 017 Dobson DaVanzo & Associates, LLC. All Rights Reserved. 6

Dobson DaVanzo s HHGM Replication Results: Key Findings The HHGM is highly redistributive of Medicare payments for home health services* 7% of HHAs would experience a revenue shift of at least +/- 0% for the same cases under HHGM 41% of HHAs serving ACO-attributed beneficiaries would experience a revenue shift of at least +/- 0% for the ACO-attributed case load under HHGM Note that the inclusion of overhead dollars derived from cost reports in the analysis may reassign payments to case types that facilitybased providers specialize in, further exacerbating redistributional effects of the system Major drivers of the impact ratio are therapy provided, admission source (institutional vs. community), timing (early vs. late), and presence of comorbidities *Note this distribution assumes a budget neutral system; As outlined in the proposed rule and our analyses, HHGM is not budget neutral Source: Dobson DaVanzo analysis of 013 VRDC RIF data, CMS Data Use Agreement Number 868. 017 Dobson DaVanzo & Associates, LLC. All Rights Reserved. 7

The Proposed Rule s Illustration of 60-day Episodes and 30-day Simulated Periods 8.64m actual 30-day periods /10.m potential 30-day periods* = 85% *5.11m initial 60-day episodes x = 10.m potential 30-day periods Source: Proposed Rule: Medicare and Medicaid Programs; CY 018 Home Health Prospective Payment System Rate Update and Proposed CY 019 Case-Mix Adjustment Methodology Refinements; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements. 8 Federal Register 144, page 3530. Centers for Medicare and Medicaid Services. July 8, 017. https://www.gpo.gov/fdsys/pkg/fr-017-07-8/pdf/017-1585.pdf. 017 Dobson DaVanzo & Associates, LLC. All Rights Reserved. 8

Dobson DaVanzo s Analysis of the HHGM Impact as Outlined in the Proposed Rule HHGM as outlined in the CY018 proposed rule is an estimated 15% below budget neutral on revenues due to the exclusion of certain 30-day episodes which are currently paid under the 60-day system 1 Proposed Rule: Medicare and Medicaid Programs; CY 018 Home Health Prospective Payment System Rate Update and Proposed CY 019 Case-Mix Adjustment Methodology Refinements; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements. 8 Federal Register 144. Page 3598. Centers for Medicare and Medicaid Services. July 8, 017. https://www.gpo.gov/fdsys/pkg/fr-017-07-8/pdf/017-1585.pdf. Ibid. Page 3530. 017 Dobson DaVanzo & Associates, LLC. All Rights Reserved. 9

Dobson DaVanzo s Analysis of the HHGM as Outlined in the Proposed Rule Subsequent to our replication of the 013 HHGM, a revised version of the model was included in the CY018 HH PPS proposed rule. Despite this revised version, Dobson DaVanzo s overall conclusion that the system is highly redistributive is unchanged However, despite our efforts to recreate and analyze the HHGM, we are unable to fully understand its impacts due to unclear or missing information Fundamental to understanding the impact table is to know the baseline system revenue from which impacts are assessed The 4.3% reduction to home health payments described in the proposed rule appears to rest on assumptions on [agency] behavioral responses. 1 What are the assumed behavioral responses that would decrease the apparent 15% reduction in revenue to a lesser 4.3%? The implications of the changes to LUPA and high-cost outlier episodes and questionable encounters may reflect changes to the home health benefit The distribution of resource use for dually (Medicare and Medicaid) eligible beneficiaries found in the Abt Technical report contradicts previous literature The HHGM as outlined in the proposed rule was modeled using 016 data, which is not publicly available 1 Proposed Rule: Medicare and Medicaid Programs; CY 018 Home Health Prospective Payment System Rate Update and Proposed CY 019 Case-Mix Adjustment Methodology Refinements; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements. 8 Federal Register 144, page 3598. Centers for Medicare and Medicaid Services. July 8, 017. https://www.gpo.gov/fdsys/pkg/fr-017-07-8/pdf/017-1585.pdf. Ibid. Page 35385. 017 Dobson DaVanzo & Associates, LLC. All Rights Reserved. 10

Points to Consider The HHGM represents a major shift from the current payment system The HHGM has the potential to significantly redistribute payments and revenues By setting costs equal to payments, the HHGM essentially rebases the system to a lower level Paired with the lack of budget neutrality, the HHGM would stress the system in compounding ways and potentially create unintended consequences Historically, changes of this magnitude have placed agencies in jeopardy, with negative impacts on beneficiaries, providers, and the post-acute care landscape 017 Dobson DaVanzo & Associates, LLC. All Rights Reserved. 11