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

Similar documents
The Home Health Groupings Model (HHGM)

Medicare Home Health Prospective Payment System

2017 Home Health PPS Rate Update

CY 2018 Home Health PPS Proposed Rule

Medicare Home Health Prospective Payment System Calendar Year 2015

September 25, Via Regulations.gov

CY2019 Proposed Medicare Home Health Rate Rule and Much More

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

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

Medicare Home Health Prospective Payment System

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

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

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

September 22, 2017 VIA ELECTRONIC SUBMISSION

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

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

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

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

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

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

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

Overview of the Hospice Proposed Rule

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

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

HOMECARE AND HOSPICE REIMBURSEMENT

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

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

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

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

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

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

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

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

Division C: Increasing Choice, Access, and Quality in Health Care for Americans TITLE XV: Provisions Relating to Medicare Part A

MEDICARE PROGRAM; FY 2014 HOSPICE WAGE INDEX AND PAYMENT RATE UPDATE; HOSPICE QUALITY REPORTING REQUIREMENTS; AND UPDATES ON PAYMENT REFORM SUMMARY

MedPAC June 2013 Report to Congress: Medicare and the Health Care Delivery System

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

PPS: The Big Picture

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

Hospice Program Integrity Recommendations

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

Healthcare Reimbursement Change VBP -The Future is Now

Home Health Market Overview

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

August 30, Submitted electronically

Payment Rule Summary. Medicare Inpatient Psychiatric Facility Prospective Payment System: Update Notice for Federal Fiscal Year 2013

Medicare Inpatient Psychiatric Facility Prospective Payment System

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

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

HEALTH PROFESSIONAL WORKFORCE

Hospital Rate Setting

Prepared for North Gunther Hospital Medicare ID August 06, 2012

Medicare Claims Processing Manual Chapter 10 - Home Health Agency Billing

Topics to be Ready to Present if Raised by the Congressional Office

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

MEDICARE INPATIENT PSYCHIATRIC FACILITY PROSPECTIVE PAYMENT SYSTEM

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

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

August 25, Dear Acting Administrator Slavitt:

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

Rural Health Disparities 5/22/2012. Rural is often defined by what it is not urban. May 3, The Rural Health Landscape

Medicare Skilled Nursing Facility Prospective Payment System

National Partnership for Hospice Innovation 1299 Pennsylvania Avenue NW Suite 1175 Washington, DC 20004

New in Current payment risks. Tips & strategies. Revenue Cycle: The Ca$h Connection. CPAs & ADVISORS

Final Rule Summary. Medicare Skilled Nursing Facility Prospective Payment System Fiscal Year 2017

MI Health Link Calendar Year 2016 Medicaid Capitation Rate Development

Proposed Rule Summary. Medicare Inpatient Psychiatric Facility Prospective Payment System: Federal Fiscal Year 2015

LTCH Payment Reform & Patient Criteria

Overview of Select Health Provisions FY 2015 Administration Budget Proposal

Inpatient Hospital Rates Rebasing Report

Working Paper Series

August 25, Dear Ms. Verma:

Medi-Cal APR-DRG Updates. Medi-Cal Updates. Agenda. Medi-Cal APR-DRG Updates Quality Assurance Fee (QAF) Program

Home Health: Federal Challenges and Opportunities

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

Program Focus. Affordable Care Act: What is in store for home care? 4/2/2015. The State of Home Care and Hospice:2015. Missouri Alliance for Home Care

Michigan. Source: Data collected by George Washington University for MACPAC Back to Summary. Date Last Searched. Documentation Date

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

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

Preventable Readmissions Payment Strategies

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

2014 MASTER PROJECT LIST

Preventable Readmissions

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

Final Rule Summary. Medicare Skilled Nursing Facility Prospective Payment System Fiscal Year 2016

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

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

Moving the Dial on Quality

HOSPICE TARGETED PROBE & EDUCATE Melinda A. Gaboury, COS C Healthcare Provider Solutions, Inc.

Medicare and Medicaid Programs; CY 2015 Home Health Prospective Payment System

Decrease in Hospital Uncompensated Care in Michigan, 2015

Inpatient Hospital Rates Rebasing Report

Dobson DaVanzo & Associates, LLC Vienna, VA

January 2017 A GUIDE TO HOME HEALTH VALUE-BASED PURCHASING

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

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

Executive Summary. This Project

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

2017 OIG Work Plan and Current Compliance Topics - Home Health and Hospice

Transcription:

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

Hospice Challenges Past & Present Face-to-Face (F2F) Implementation Sequestration Cuts BNAF Phase-out Payment Reductions Affordable Care Act (ACA) payment reductions Significant Payment Model Change (1-60/61+, SIA) Hospice Compare Hospice Item Set (HIS) Down the Road Continued Improvement in Palliative Care needed Potential for additional revisions to payment model HEART implementation

Home Health Challenges Face-to-Face (F2F) Implementation, several revisions Sequestration Cuts Affordable Care Act (ACA) payment reductions 14% Rebasing Cut (from ACA) Improper Payment Rate & Increased Audit Activity Pre-Claim Review Demonstration (PCRD) Conditions of Participation (COP) Significant Update Home Health Groupings Model (HHGM) Proposal Rural Add-on Payment Expiration

9 Straight Years of CMS HH Rate Cuts Summary of CMS Home Health Rate Changes Rate Change Component 2009A 2010A 2011A 2012A 2013A 2014A 2015A 2016A 2017A 2018E MACRA MBU Net 1% Update (1.70%) ACA Market Basket Reduction (1.00%) (1.00%) (1.00%) Case Mix Creep (2.75%) (2.75%) (3.79%) (3.79%) (1.32%) (0.90%) (0.90%) (0.90%) Productivity Adjustment (3) (0.50%) (0.40%) (0.30%) Rebase (2.73%) (2.40%) (2.40%) (2.30%) Outlier Cap (5) (2.50%) Base Rate Adj. Outliers (6) 2.50% (2.50%) Grouper Changes (0.62%) Sequestration (2.00%) Rural Add On (8) 0.24% (0.50%) Revised FDL 0.31% Wage Index (8) (0.28%) 0.05% 0.08% (0.30%) Total Reductions (2.75%) (5.53%) (7.29%) (4.79%) (4.62%) (3.35%) (2.90%) (3.70%) (3.50%) (3.10%) Cumulative Reductions (2.75%) (8.28%) (15.57%) (20.36%) (24.98%) (28.33%) (31.23%) (34.93%) (38.43%) (41.53%) Market Basket Update (9) 2.90% 2.00% 2.10% 2.40% 2.30% 2.30% 2.60% 2.30% 2.80% 2.70% Total Rate Changes 0.15% (1.03%) (4.90%) (2.31%) (2.01%) (1.05%) (0.30%) (1.40%) (0.70%) (0.40%) Cumulative Net Rate Changes 0.15% (0.88%) (5.78%) (8.09%) (10.10%) (11.15%) (11.45%) (12.85%) (13.55%) (13.95%) Cumulative Reductions: (41.53%) Cumulative Net Rate Change: (13.95%)

Prioritizing Current HH Activities Face-to-Face (F2F) Relief Legislation Pre-Claim Review Demonstration (PCRD) v2.0 Conditions of Participation (COP) Implementation Home Health Groupings Model (HHGM) Proposal Rural Add-on Payment Expiration Others Out of all of these challenges and current priorities, none come close to the importance of HHGM. Payment reduction could be much higher than CMS estimates 24 counties in US have 100% of existing providers go from positive to negative margins under a budget-neutral HHGM and all are rural geographies (81 have at least half of existing providers do the same). Access to Care issues are likely to occur under HHGM

HHGM BACKGROUND 6

Legal Context Section 3131(d) of the Affordable Care Act (ACA) emphasizes the importance of HHAs maintaining on going access to care for vulnerable populations. These vulnerable populations are identified as low income, live in underserved areas, and have a high severity of illness. 1 Section 3131(d) authorized a study on costs and payments associated with these vulnerable populations, and directed payment incentives and vulnerabilities to be addressed in any revised HH payment option. The resulting Medicare Home Health Study Report to Congress confirmed that: Particular beneficiary characteristics appear to be strongly associated with margin, and thus may create financial incentives to select certain patients over others; (*) and Cost/payment structures or incentives could negatively affect HHAs on going provision of access to care for vulnerable populations. This is an important consideration for development of any alternative payment model. CMS commissioned Abt to incorporate the findings of the Report to Congress into a revised HHA payment system. * These vulnerable patient groups include patients who Sources: 1. Abt Associates. Medicare Home Health Prospective Payment System: Case Mix Methodology need parental nutrition, or have traumatic wounds or ulcers Refinements. Overview of the Home Health Groupings Model. Nov 2016. Pages 1.1 1.2, 2.1 2.3. require substantial assistance in bathing 2. Report to Congress. Medicare Home Health Study: An Investigation on Access to Care and Payment for Vulnerable Patient Populations. Pages 4 7. are admitted to home health following an acute or postacute stay 3. MedPAC. Report to the Congress: Medicare Payment Policy. March 2011. Pages 175 180. 4. MedPAC. Report to the Congress: Medicare Payment Policy. March 2015. Pages 213 224. have a higher HCC score have certain poorly controlled clinical conditions are dual eligibles 7

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 8

The HHGM s case mix groups are based on episode timing and admission source, clinical grouping, functional level and comorbidities Source: Overview of the Home Health Groupings Model. November 18, 2016. Abt Associates. https://downloads.cms.gov/files/hhgm%20technical%20report%20120516%20sxf.pdf Note: Abt s initial model contained 128 clinical groupings; the proposed rule published in July 2017 revised the number of groupings to 144 Each home health episode is put into a mutually exclusive group based on the episode s timing and the patient s admission source, clinical grouping, functional level and comorbidities Each group is associated with a particular case mix weight, which is incorporated into the payment model: Base Rate x Case Mix Weight x Other Adjustments = Episode Payment 9

Dobson DaVanzo s HHGM Replication Results: Key Findings The HHGM is highly redistributive of Medicare payments for home health services* 27% of HHAs would experience a revenue shift of at least +/ 20% for the same cases under HHGM 41% of HHAs serving ACOattributed beneficiaries would experience a revenue shift of at least +/ 20% for the ACOattributed 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 facility based providers specialize in, further exacerbating redistributional effects of the system *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 2013 VRDC RIF data, CMS Data Use Agreement Number 28682. 10

HHGM is substantially below budget neutral before accounting for possible behavioral offsets As described in the proposed rule, HHGM revenues are derived by: Calculating the 60 day base episode payment rate. Dividing it in half to apply to 30 day episodes. However, the transition from 60 day episodes to 30 day episodes invalidates 15.4% of 30 day episodes without compensating for the decrease in revenues. In other words, there are periods of time where coverage was paid under the old system that would no longer be paid under the new system. The base payment rate is not adjusted to account for this difference. There are additional episodes excluded from the analytic file that were paid under current law. E.g. Episodes that did not link to HHGM clinical group or to an OASIS assessment. It is unclear what portion of HH PPS payments these cases represent. These may be largely compensated for in agency coding changes under the HHGM rules. 11

The Proposed Rule s Illustration of 60 day Episodes and 30 day Simulated Periods 8.64m actual 30 day periods /10.22m potential 30 day periods* = 85% *5.11m initial 60 day episodes x 2 = 10.22m potential 30 day periods Source: Proposed Rule: Medicare and Medicaid Programs; CY 2018 Home Health Prospective Payment System Rate Update and Proposed CY 2019 Case Mix Adjustment Methodology Refinements; Home Health Value Based Purchasing Model; and Home Health Quality Reporting Requirements. 82 Federal Register 144, page 35302. Centers for Medicare and Medicaid Services. July 28, 2017. https://www.gpo.gov/fdsys/pkg/fr 2017 07 28/pdf/2017 15825.pdf. 12

Dobson DaVanzo s Analysis of the HHGM Impact as Outlined in the Proposed Rule HHGM as outlined in the CY2018 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 2018 Home Health Prospective Payment System Rate Update and Proposed CY 2019 Case Mix Adjustment Methodology Refinements; Home Health Value Based Purchasing Model; and Home Health Quality Reporting Requirements. 82 Federal Register 144. Page 35298. Centers for Medicare and Medicaid Services. July 28, 2017. https://www.gpo.gov/fdsys/pkg/fr 2017 07 28/pdf/2017 15825.pdf. 2 Ibid. Page 35302. 13

Behavioral Response Assumptions?

Transparency: A Call for Continued and Deeper Industry Involvement Transparency and continued stakeholder input throughout the development and implementation of HHGM is critical to maintaining market stability and access to care for patients. Transparency is particularly important given HHGM s complexity and ultimate impact on both provider supply and patient access to HH services. Complete information on how the model was constructed will help providers understand how future episode payments will be derived. CMS/Abt should provide the algorithms used to link Medicare claims data, cost reports, and OASIS assessment data to help providers fully replicate the final data set and understand the analyses conducted. CMS/Abt should also provide a grouper tool that allows agencies to simulate the proposed two 30 day periods within a 60 day episode in order to determine the impact HHGM will have on their own operations and financial stability. CMS should continue to solicit stakeholder input regarding the HHGM framework and how the model will change HHAs operations and patient care. 15

HHGM Changes are Extensive Payment Components Current HHGM Episode Payment Period 60 Days 30 Days RAP Billing Frequency 1x per 60 Days 2x per 60 Days Final Claim Billing Frequency 1x per 60 Days 2x per 60 Days Resource Utilization Basis Bureau of Labor Statistics Data Medicare HHA Cost Reports NRS Payments Episodic Add-on Payment Incorporated into Base Rate Therapy Service Payments Service threshold payments Incorporated into Case Mix Early/Late Designations 1 st & 2 nd Episodes are Early 1 st 30 day periods are Early Referral Source-based Payment Adj. None 2 Different Categories Patient Comorbidity Payment Adj. None Included in Certain 30-day Periods LUPA Visit Threshold 1 Threshold (<=4 Visits) 6 Different Thresholds (<2-7 Visits) Functional Level Patient-centric determined HHGM Group-centric determined Outlier Payment Adjustment Each 60-day Episode Each 30-day Period Clinical Need/Classification OASIS Scoring (C1-C3) 6 Clinical Categories Questionable Encounters N/A 23% of total 30-day Periods

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 29%, from 104 home health users per 1,000 in 1996 to 72 users per 1,000 in 1999 2 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 2007 3 1 Note: The actual closure rate was 26%; 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 2003. https://aspe.hhs.gov/system/files/pdf/74761/closings.pdf. 2 Note: Average county level rate of decline in HHA utilization. Source: Ibid. Page 6. 3 Note: Program payments were $15.6 billion in 2007. Source: Health Care Financing Review 2008 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 2007. Centers for Medicare and Medicaid Services. https://www.cms.gov/research Statistics Data and Systems/Statistics Trends and Reports/MedicareMedicaidStatSupp/Downloads/2008_Section7.pdf#Table%207.1. 17

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 18

Materials Recently Made Available

What s Ahead? Summary In spite of the challenges, we KNOW that home-based care is vital to our nation s healthcare future Our country cannot afford a care delivery system that at its core lacks a thriving, effective and efficient home health industry. Technology will continue to allow better care to be provided in the most cost-effective and patient-preferred setting the home. Our industry MUST effectively illustrate and share our value proposition We have countless amazing stories of helping and healing in the home Shame on us if we don t believe enough in what we do to tell our stories With Great Knowledge Comes Great Responsibility We must collect, analyze, interpret, understand, and use our data Data is a powerful resource that allows us to standardize our care with respect to clinically appropriate and cost-effective interventions