Will HHGM be delayed?

House bill would delay new payment model until 2020,
but agencies still have work to do. Here are 3 priorities.

It’s been a year of remarkable regulatory suspensions and delays for the home health industry – sometimes at the last minute  – and home health agencies are wondering whether another regulatory reprieve could be in the works.

A bill introduced late last week in the U.S. House of Representatives would postpone the costly and controversial overhaul of the Medicare payment system known as the Home Health Groupings Model (HHGM) which CMS proposes to implement in 2019.

Agencies would not see implementation of the proposed HHGM until 2020 under HR 3992, the bill introduced last Friday by Rep. Kristi Noem (R) of South Dakota.

“But it is important to note that the bill in its current form will not address expected losses of as much as $950 million in the first year of implementation due to reduced payments to home health agencies,” said J’non Griffin, owner and president of Home Health Solutions.

HR 3993, or the Rural Home Health Extension and Regulatory Relief Act, does not affect the proposed new 30-day payment episode in the HHGM or the shift away from a therapy-driven payment model to a new system which relies on clinical groupings, J’non said.

“Whether it is implemented in 2019 or a year later, under this proposed bill, the new payment system will still be a coding and OASIS driven payment model,” J’non said. “With that in mind, agencies can begin some important preparations.” She recommends that agencies take the following 3 steps to prepare:

  1. Focus on improved coding accuracy. 

The new HHGM relies heavily on primary diagnoses codes to classify each 30-day episode into one of six clinical groupings. Comorbidities, early or late timing of the episode, admission source and the patient’s cognitive and functional status are also integral to the new classification.

Under the new model, episodes which could not be grouped by primary diagnoses due to coding issues would be considered “questionable encounters” and returned to the provided for more accurate or definitive coding.

Whether agencies rely on in-house coders or outsource coding services, the quality of an agency’s coding will determine its viability under the HHGM, J’non said.

“Some agencies which may have been reluctant to outsource coding services are going to have to make that move, under the new HHGM, to ensure the level of accuracy needed for success, “she said. “And that decision is going to open up new areas of compliance risk, requiring agencies to look beyond cost to determine the credentials of the coders and quality of the services provided. It’s definitely a case of buyer beware in the coding world. If the price seems to be an exceptional bargain, smart agencies should wonder how and ask why.”

2. Provide thorough OASIS C-2 training to all team members.

As part of the HHGM case-mix adjustment, CMS proposes to assign points for each of the responses to certain OASIS functional items. The sum of those points would create a functional score for the period of care. Items to be scored are:

● M1800: Grooming.

● M1810: Current Ability to Dress Upper Body.

● M1820: Current Ability to Dress Lower Body.

● M1830: Bathing.

● M1840: Toilet Transferring.

● M1850: Transferring.

● M1860: Ambulation/Locomotion.

● M1032 (M1033 in OASIS-C1): Risk of Hospitalization.

“OASIS mistakes will be costly under the new HHGM,” J’non warns. “Agencies which may have been reluctant to invest in OASIS training in the past need to make that commitment now. It’s important to note, too, that just because clinicians have had training in the past doesn’t necessarily mean they’re up to speed. Guidance changes frequently in this field – and complete reversals are not unusual. Accuracy requires ongoing training.  Training does pay for itself, directly impacting an agency’s bottom line.”

3. Estimate the HHGM impact on your agency by using a CMS tool.

Determining how the HHGM will impact your agency is a crucial first step in developing plans to stabilize your bottom line. CMS has put together a grouping tool to help agencies understand how the proposed payment grouping parameters would impact payments.

To use it, your agency will need to input several months of data from patients under the current system and see how much of a difference the new payment model would make on payments received.

Click here to access the Excel file available on the CMS web site at http://go.cms.gov/2f12QpC.