Three Key Updates to HHVBP in 2024: What Your Home Health Agency Needs to Know

Updates in the 2024 Home Health Final Rule

On November 1, 2023, CMS released their CY 2024 Home Health Final Rule, which included updates and policy changes for home health agencies. Among the changes were several updates to Home Health Value-Based Purchasing (HHVBP) that are important for agencies to plan for because these changes will impact future reimbursement. 

Here are the three changes in the 2024 Home Health Final Rule which will affect HHVBP in the first payment year of 2025 and beyond: 

• Discharge Function Score replaced the two Total Normalized Composite Measures (for self-care and mobility).
• The claims-based ‘Discharge to Community-Post Acute Care’ (PAC) measure for home health agencies replaced the OASIS-based ‘Discharge to Community’ (DTC) measure. 
• The claims-based ‘Potentially Preventable Hospitalization’ measure replaced the claims-based ‘Acute Care Hospitalization During the First 60 Days of Home Health Use’ and the ‘Emergency Department Use Without Hospitalization During the First 60 Days of Home Health’ measures.

Reimbursement rates and other major changes will often be the central focus during regulatory season, but OASIS changes and updates to HHVBP make a huge impact on an agency’s long-term health and, therefore, need to be planned for and acted on before important changes take effect.

Industry Expert Cindy Krafft Explains What This Means for Your Agency

During a recent MedBridge webinar, industry expert Cindy Krafft, owner of K&K Health Care Solutions, discussed the important role of the frontline clinician on the agency’s overall results, stating:

“I see a lot of hand-wringing from leadership about value-based purchasing—but if the clinician is not engaged, you will not achieve the results you want to achieve. The only thing that moves the needle is the frontline clinician providing the care.”

Planning for these changes often requires updating education materials and training staff on a new process, and this takes time. However, as a member of CMS’ Home Health Technical Expert Panel (TEP) herself, Krafft stated, “The TEP expressed concern that fewer than 30 percent of agencies even opened their IPR report.” This refers to the Interim Progress Report (IPR) released last year by CMS that provides home health agencies with a ‘report card’ on their performance. An agency failing to open their IPR would indicate that they don’t understand how their quality compares with available benchmarks, nor have they reviewed areas of improvement highlighted by the report. Instructions for agencies on how to access their IPR are available from CMS—it’s not too late to access those reports and take action.

Krafft also contends that not enough comments were provided to CMS regarding the transition to discharge functional score. “What is true today is not what’s going to be true with the Final Rule,” stated Krafft, explaining that while certain elements of (OASIS) Section GG were adopted, not all GG items are present—bathing, dressing, and several other functional areas that are focused on in home health are not available. These items are not available in other settings, and therefore can’t be standardized as required by the 2014 Impact Act, but Krafft expressed concern that this small but important detail may have been missed unless agencies were looking closely.

However, Krafft stated, “Nothing is changing about PDGM and Home Health Compare, and they will still utilize those elements, so don’t throw the M-1800s out; you’re still going to have to have accurate data and outcomes.” Essentially, the HH elements of section GG have been taken out of HHVBP, but they still impact their payment in PDGM. So don’t over-focus on just what you need to do to succeed with HHVBP and miss what is important to the patient and the rest of the payment.

She also expressed concern that many of the elements selected are required for discharge from the hospital and therefore would not have the potential for showing improvement, leading to lower scores and lower payment for home health agencies unless these areas are carefully documented. 

How Can My Agency Prepare?

Agencies need to lay the groundwork to perform well and receive the full reimbursement for the care they provide. Experts point to foundational skills such as accurate OASIS data collection, having an effective QAPI process, and ensuring emergency department visits and hospitalizations are reduced as keys for success in HHVBP. 

Agencies should also not forget that CMS included a reminder in the 2024 Home Health Final Rule that public reporting of HHVBP performance data and payment adjustments will begin in December 2024. 

Ready to help your agency prepare and succeed under HHVBP in 2025 and beyond? We have you covered with plenty of resources.

You can register for our upcoming webinar on January 30th, 2024 at 1PM ET/10AM PT, Home Health Value-Based Purchasing: Lessons Learned From the First Performance Year, with SimiTree Healthcare Consulting’s Clinical Director, Charles Breznicky.

Our recorded webinar with home health expert Cindy Krafft, 2024 Strategies for Home Health: CMS Final Rule, Oasis-E, and HHVBP, is available to view anytime on-demand.

For more information on how MedBridge can help your agency thrive with HHVBP, request a demo of our Home Health Value-Based Purchasing Solution.