The launch of the Home Health Value-Based Purchasing (HHVBP) model. A major change to the Outcome and Assessment Information Set (OASIS). New rules going into effect for Electronic Visit Verification (EVV). These are all initiatives that commenced this week.
The beginning of a new calendar year typically triggers the start of new or amended regulatory initiatives. Here are some of the major ones now in effect:
1. HHVBP
After much discussion and back-and-forth with home health providers, the Centers for Medicare & Medicaid Services has expanded the HHVBP program to all 50 states. The program pits home health providers against their peers based on performance against a set of three quality measures: OASIS data, completed Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) surveys and claims-based measures.
The biggest change to the program occurred in November when CMS set the final baseline year for the expanded model as calendar year 2022, rather than CY2019.
Noted Katy Barnett, director, home care and hospice operations and policy, LeadingAge, the association of nonprofit providers of aging services: “We understand why CMS decided to do this and know that the agency did its due diligence in looking at the impact of COVID on home health measures used to assess providers. But the result is that providers, who had for most of the year been working from CY2019 quality scores and information, are now in a tough position, having to scramble to update based on CY2022 data.”
2. OASIS update
Barnett noted that on top of HHVBP, home health providers are “staring down the biggest change to the OASIS in nearly a decade.”
The instrument was set to be implemented on Jan. 1, which had software providers scrambling at the end of 2022 to make software updates, she said.
“And for providers, the new OASIS tool will require that their staff devote more time on upfront assessments — which creates a fresh challenge in workplaces already experiencing tight staffing, with a premium on wise and efficient use of time,” Barnett said in an email.
3. EVV rules for home health
Following the passage of the 21st Century Cures Act in December 2016, as of Jan. 1, states must require EVV for all Medicaid-funded home healthcare services, according to CMS.
“Otherwise, the state is subject to incremental FMAP reductions up to 1% unless the state has both made a ‘good faith effort’ to comply and has encountered ‘unavoidable delays,’” CMS said.
EVV is a system that electronically verifies the occurrence of home- or community-based visits to ensure that individuals who are authorized for services get the care they need and to help combat home care Medicaid fraud. CMS required EVV for all Medicaid-funded PCS by Jan. 1, 2020.
4. ACO REACH
Despite the pushback from federal lawmakers, the Accountable Care Organization Realizing Equity, Access, and Community Health (ACO REACH) began on Jan. 21.
ACO REACH replaces the Global and Professional Direct Contracting (GPDC) model to better coordinate care across underserved communities. The program is designed to shift providers from fee-for-service to a value-based care payment system.
Sen. Elizabeth Warren (D-MA) and Rep. Pramila Jayapal (D-WA) along with several other lawmakers sent a letter to CMS expressing concerns about the new program’s potential for fraud. They asked the agency to act “by at the very least halting participation by any organizations that have committed healthcare fraud and terminating (direct contracting entities) that do not meet the new standards for the ACO REACH program,” the letter stated.
5. Discontinuation of certain forms related to durable medical equipment (DME)
As of Jan. 1, CMS has eliminated Certificated of Medical Necessity (CMN) and DME Information Forms (DIFs). Originally, CMS required CMN and DIF forms to help document medical necessity and other coverage criteria for DME. For services on or after Jan. 1, applicable providers, suppliers, billers and vendors should not submit CMN or DIF forms or their electronic claim data elements with the claims. The rule applies to providers, suppliers, billers and vendors who bill DME Medicare Administrative Contractors (MACs) for services and supplies they provide to Medicare patients.
