HCBS caregiver speaks with a patient receiving LTSS.

In an October report, the Better Medicare Alliance (BMA) called for more thorough and transparent reporting of in-home health risk assessments (HRAs). The move follows concerns that these assessments could be improperly used to inflate Medicare Advantage risk-adjusted payments.

“In-home HRAs have long been an important tool to understand and address the comprehensive social, emotional and physical health needs and understanding of beneficiaries,” BMA said in its report. “At the same time, policymakers have expressed concern over the appropriate use of in-home HRAs and the connection to risk adjusted payments in Medicare Advantage.”

In 2020, the Office of the Inspector General investigated HRA use among MA Organizations, and discovered that billions of dollars had been paid out due to improper in-home HRA practices. These findings “raise concerns about the completeness of payment data submitted to CMS, the validity of diagnoses on HRAs, and the quality of care coordination for beneficiaries,” OIG said in its report.

To improve the value, transparency and accountability of these assessments, BMA made a number of recommendations. First, the Centers for Medicare & Medicaid Services should mandate that health plans report their total number of in-home HRAs conducted, appointments scheduled that are a result of an HRA, and instances where other reports like medication reviews are conducted, BMA advised. And BMA called for health plans to deliver beneficiaries’ HRA results to their primary care provider, as well as ensuring that the assessments themselves are compliant with all CMS guidelines.

Finally, BMA advocated for an expanded “best practices” standard for in-home HRAs, and continued attention to ensure the assessments are conducted in accordance with regulation.

“BMA encourages CMS to take additional steps to ensure in-home HRAs are available as a tool for health plans to assess the overall social, emotional, and physical health of beneficiaries, document diagnoses, and identify gaps in care,” the report noted.

In its report, BMA also mentioned other goals such as enhancing supplemental benefit data collection and advancing health equity among beneficiaries.