The Home Health Grouping Model (HHGM) and the Cost of Bad Data
Posted on Wednesday, February 22, 2017 2:34 PM
The Centers for Medicare & Medicaid Services (CMS) contracted with Abt Associates (Abt) to develop a new payment methodology for the home health industry. One of the first areas they explored was agency cost associated with performing visits. The research teams considered several methods for determining the cost. They highlighted two models in the Home Health Grouping Model (HHGM) technical report.
One of the models explored is the continual use of the current model (ref. CMS 1648-F, page 76707) Wage Weighted Minutes of Care (WWMC). WWMC looks at an annual calendar’s worth of claim data (for 2017, they used 2015 data) for each of the six home health disciplines in 15-minute increments to determine the number of clinical and function variable points to assign in the case mix calculation. There is a significant concern with this methodology. Home health agencies should be reporting discipline visit times in 15-minute increments on claims. Because of bundle billing, some agencies do not feel that it is needed to report this level on detail. This is comparable to the situation that the home health industry created in the early 2000’s when agencies were not properly reporting supply cost. When CMS looked at claims data to determine supply cost in bundle billing, they used the inaccurate data which lead to minimal supply reimbursement that agencies receive now. This model also does not account for cost, such as transportation or non-visit services labor costs which included documentation time outside of the home.
The other model is Cost per minute plus Non-Routine Supplies (CPM + NRS) which uses information from Medicare Cost Reports (MCR). Like the WWMC concern on if visit times are being properly reported, there has been a historic concern if MCR are accurate. Under reporting of data on MCR can hurt the whole industry when CMS is using the data to determine a new payment model. CPM + NRS model looks at MCR to calculate the number of visits per discipline and looks at average NRS cost for each episode. The technical report states that “a significant number of episodes being reimbursed for NRS despite not reporting any NRS charges on the claim.” This is again concerning because supply cost maybe under reported which will continue to lead to under reimbursement for in the future.
It has not been publicly announced if and when a new payment methodology for home health will occur. What is very clear is that inaccurate data either on claims or MCR will lead to decreased reimbursement to the whole home health industry. As an industry, we should warrant enforcement of proper standards of claims data and MCR data to ensure agencies receive proper reimbursement for the services that are provided. The saying “bad data in bad data out” is totally applicable in CMS determining home health’s future reimbursement.
Written by Nick Dobrzelecki, Corridor’s Vice President of Coding Services