Where to Start? Foundational Learning Materials for the Expanded HHVBP Model

Leading up to CY 2023, the HHVBP TA Team will spotlight different introductory resources to guide HHAs in preparing for the first performance year of the expanded HHVBP Model. CMS and the TA Team encourage HHA staff to review the following resources available on the Expanded HHVBP Model webpage:

• · HHVBP Model Expansion 101 Live Event – In February 2022, the HHVBP TA Team hosted a live learning event: HHVBP Model Expansion 101. The team shared essential information regarding the expanded HHVBP Model, including topics such as participation criteria, cohort assignment, quality measures, payment adjustment methodology, and performance feedback reports. The learning event concluded with a live Q&A session.
• · Expanded HHVBP Model Frequently Asked Questions (FAQs) – Routinely updated, the FAQs assist HHAs in understanding common terms used in the expanded HHVBP Model and requirements under the CY 2022 Home Health Prospective Payment System (HH PPS) final rule. The HHVBP TA team provides updates to the FAQs as needed and notifies HHAs that have signed up to receive communications when an updated version is available on the Expanded HHVBP Model webpage.
• · Expanded HHVBP Model Guide – The Model Guide includes an overview of the expanded Model, information on eligibility and cohorts, quality measures used in the expanded Model, Total Performance Score (TPS) methodology and payment adjustment methodologies, and an overview of the performance feedback reports.

If you have questions about implementation of the expanded HHVBP Model, please email the HHVBP Help Desk at hhvbpquestions@lewin.com

Calendar Year (CY) 2023 Medicare Physician Fee Schedule Released

The Centers for Medicare & Medicaid Services (CMS) has finalized changes in CMS’s annual Physician Fee Schedule (PFS) proposed rule to significantly expand access to behavioral health services and moves the health system closer to achieving equitable outcomes through high quality, affordable, person-centered care. These changes will ensure CMS continues to deliver on our goals of advancing health equity, driving accountable care, and protecting the sustainability of the Medicare program.

Building on the CMS Innovation Center’s successful ACO Investment Model (AIM), CMS is changing the Medicare Shared Savings Program to make more Accountable Care Organizations (ACOs) available in rural and underserved areas, which builds upon our continuing efforts to advance health equity. We are launching a payment adjustment for ACOs that reward them when they provide excellent care to underserved populations.

The Innovation Center also sought comment on an alternative approach to calculating ACO historical benchmarks that would use administratively set benchmarks that are decoupled from ongoing observed FFS spending including the design of the approach, as described in the Request for Information (RFI). CMS has observed that the benchmarking methodology for the Shared Savings Program and Innovation Center models may include ratchet effects that reduce benchmarks for successful ACOs and jeopardize their continued participation over multiple agreement periods, resulting in selective participation (including limited participation by inefficient ACOs). The RFI gathered information regarding the future use of administrative benchmarking, and comments will be considered for future rulemaking.

For more information, please see the PFS press release.

Focus Group Study: 30% Believe Hospice Intentionally Hastens Death

Hospice News / By Holly Vossel

About 30% of participants in a recent study said they believe that “hospice intentionally hastens death and the dying process.”

The data appeared in a recently developed evidence-based serious illness messaging toolkit from the MessageLab Serious Illness Messaging Project. The toolkit identifies new approaches for hospice and palliative care providers to break down barriers of public misperception and apprehension of their services.

One key consideration in hospices’ public messaging is that, in today’s media and technology climate, consumers access information quickly and in small doses. This means hospices have to achieve more with less in their efforts to reach consumers, according to Dr. Tony Back, primary investigator at the MessageLab Serious Illness Messaging Project.

“We have to stop trying to confront people about dying and expecting them to accept that in some kind of social media or video post. It’s just not going to happen,” Back told Hospice News. “We’re not gaining a new consumer audience or increasing public awareness in hospice and palliative. We’re not improving levels of misconception that exist about our field. There are messaging principles we can employ to improve how hospices introduce their work to the public.”

Back is also a professor of medicine and palliative care physician at the University of Washington in Seattle, co-director at the Cambia Palliative Care Center of Excellence, and co-founder of VitalTalk.

Public misunderstandings about hospice and palliative care have long-plagued the field. Hospice providers have continuously sought marketing and outreach strategies that demonstrate the benefits and value of their services to patients and families.

But many hospices’ public messaging approaches fall short of what’s needed to dispel myths, alleviate fears, and improve awareness, according to researchers.

MessageLab researchers reviewed a wide variety of public messaging, designs and other marketing components and analytics in the hospice and palliative care space to uncover common trends and issues. Armed with this information, they developed guidelines for improved communication.

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Hospice Leaders Call for Overhaul of Regulation

Hospice News / By Holly Vossell

Hospice providers are calling on regulators to change their approaches to enforcement due to the cost burden and the unpredictable nature of the dying process.

The U.S. Centers for Medicare & Medicaid Services (CMS) and the U.S Department of Health & Human Services Office of the Inspector General (OIG) have been cracking down on the industry with a heavy focus on patient eligibility and longer lengths of stay.

This has put hospices in a constant state of defense in today’s current regulatory climate, according to Craig Dresang, CEO of California-based YoloCares. 

“The reality is that we are in this posture of always being prepared to react and respond to the current auditing environment,” Dresang told Hospice News at the ELEVATE conference in Chicago. “We have to come together as providers with a fire and energy to insist on change from CMS, because we’re tired of playing a ‘gotcha game’ with the federal government. They’ve made the dying process a game of dates and deaths.”

Current rubrics for eligibility and length of stay are difficult to align with patients’ actual experiences at the end of life. A six-month terminal prognosis, for example, typically represents clinicians’ best guesses as to how long the patient will survive. But those predictions are not hard and fast.

This degree of unpredictability can make compliance challenging for providers, Dresang indicated.

Hospices also encounter variations in auditing practices that can impact perceptions of the provider’s performance, according to Alisa Gerke, executive director of Wisconsin-based Unity Hospice & Palliative Care.

“Some markets are set up whereby the auditor is incentivized in that the more issues they find, the bigger their paycheck,” Gerke told Hospice News during the conference. “We have to evolve and evaluate our practices and processes. We can’t afford not to have compliance more organized.”

The costs associated with these audits and other regulatory actions are high, according to Gerke.

In some cases, hospices can sometimes spend more on legal fees than they would make if the Medicare claims in question are ultimately paid, she explained.

To reduce the impact internally, hospice leaders need a system in place to identify high- and low-risk processes in terms of compliance, Gerke said. . .

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