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2024 Home Health Final Rule – VBP Could Help Improve Medicare Payments

Now in its second year, CMS’ VBP expansion gives HH agencies a chance to improve Medicare payments.
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As previously reported, the 2024 home health (HH) Medicare payment rates became effective January 1, 2024, with an estimated aggregated increase in payments of only 0.8%. January 1 also marked the beginning of the second year of CMS’ national expansion of the HH Medicare Value-Based Purchasing (VBP) demonstration project, which offers HH agencies an opportunity to improve Medicare payments.

The national expansion of HH VBP applies to all Medicare-certified HH agencies and was implemented January 1, 2023. HH agencies’ VBP performance in 2023 will determine up to a 5% positive or negative adjustment to Medicare payments in 2025, while performance in 2024 will determine up to a 5% positive or negative payment adjustment in 2026.

The VBP performance measures in 2024 remain unchanged and continue to include five based on the Outcome and Assessment Information Set (OASIS), two claims-based measures, and five HH Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey-based measures. However, the final rule did establish changes for 2025, including the following:

  • The five OASIS-based performance measures will be reduced to three by removing the discharged to community, total normalized composite (TNC) change in mobility, and TNC change in self-care measures and adding a new discharge (DC) function measure.
  • The two current claims-based measures will be replaced by two new measures, including potentially preventable hospitalization and discharge to community—post-acute care (DTC-PAC).

The HHCAHPS survey-based measures remain unchanged. The following table summarizes the performance measures and associated weights for 2024 and 2025.

2024 Measure Weights2025 Measure Weights
Performance MeasureLarger-Volume Cohort1Smaller-Volume Cohort2Larger-Volume Cohort1Smaller-Volume Cohort2
OASIS-Based Measures

Discharged to community3
Improvement in dyspnea5.8338.3336.000
Improvement in management of oral medications5.833
TNC change in mobility38.750
TNC change in self-care38.75012.500--
DC Function4--20.000
Sum of OASIS-based measures35.00050.00035.000

Claims-Based Measures

Acute-care hospitalization326.25037.500--
Emergency department use without hospitalization38.75012.500--
Potentially preventable hospitalization4--26.00037.143
Sum of claims-based measures35.00050.00035.000

HHCAHPS Survey-Based Measures

Care of patients6.0000.0006.000
Communications between providers and patients6.000
Specific care issues6.000
Overall rating of HH care6.000
Willingness to recommend the agency6.000
Sum of HHCAHPS survey-based measures30.0000.000
Sum of all measures100.000100.000

CMS provides HH agencies with Interim Performance Reports (IPRs), the most recent of which was released in January. The IPRs allow HH agencies the opportunity to track and trend performance in each of the 12 measures. HH agencies should take advantage of the IPRs and utilize them to target those measures that offer the most opportunity for improvement and incorporate such into their Quality Assurance and Performance Improvement (QAPI) programs.

With the potential to improve Medicare revenues by up to 5%, VBP offers a substantial opportunity to those HH agencies able to outperform others within their national cohort, or at least improve over their own prior-year performance. Conversely, those HH agencies whose performance does not keep pace with peers or show improvement will face a reduction in payments.

CMS has extensive resources available to HH agencies online, including training materials, QAPI tools, etc. If you have any questions or need assistance, please reach out to a professional at FORVIS.

  • 1 a b Larger-volume cohort includes HH agencies with 60 or more unique survey-eligible beneficiaries in the calendar year prior to the performance year.
  • 2 a b Smaller-volume cohort includes HH agencies with less than 60 unique survey-eligible beneficiaries in the calendar year prior to the performance year.
  • 3 a b c d e Performance measure no longer used in 2025.
  • 4 a b c Performance measure new for 2025.

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