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Stricter Compliance in Home Health: Is Your Agency Ready?

    As the demand for home health care increases and Medicare dollars go more into home-based care, it is certain that there will also be higher scrutiny for the quality of care that will be delivered. 2023 is the first full performance year of the expanded home health value-based purchasing (HHVBP) with payment adjustments realized in 2025. HHVBP has proven to be an effective tool to protect the most vulnerable patients as, based on a 2020 CMS study, 1900 home health agencies using the said model scored higher than those who do not. A decrease in both unplanned hospitalizations and emergency room visits proves that overall care quality and utilization scores have improved.

    According to the Centers for Medicare & Medicaid Services (CMS), the specific goals are to provide incentives for better quality care, explore new potential efficiency measures, and enhance the current reporting process. This means home health care organizations will be closely monitored and thus should be ready for scrutiny in terms of transparency, accountability, and compliance.

    Assess Compliance and Competency

    The need for upskilling and maintaining clinical staff competency poses a greater challenge for home health businesses amid the ongoing struggles with recruitment and retention. It is crucial for agencies to start looking internally within their organizations and proactively find ways to get ahead in this new era of compliance. The following are key areas to assess:

    1. Risk management and QAPI
    • Assess timeframe and process owners for reviewing regulations, creating new education, and updating compliance records.
    • Review the process for identifying and correcting any emergent problems. 
    • Revisit the metrics to validate compliance to care quality standards.
    1. Survey preparedness
    • Set frequency for reviewing federal and state regulatory updates and revising training modules.
    • Maintain up-to-date validation of staff compliance.
    • Conduct mock surveys to identify and correct areas of concern.
    • Review emergency preparedness procedures and infection control processes.
    • Establish metrics to validate staff compliance with updated federal and state regulations.
    1. Competency management program
    • Document how your agency manages the clinical staff’s competencies to care for higher-acuity patients. 
    • Evaluate and define best practices used and methods of recording to validate staff competence.
    • Streamline the process of tracking staff competencies by automating their recording and tracking.
    1. Re-education for clinicians
    • Use your comprehensive competency management program to establish learning mechanisms and re-education for your clinicians. 
    • Look for trends, recurring errors, or areas for improvement in your clinicians’ documentation using data from their charts. 
    • Create coaching programs and incentive opportunities for improved performance.
    • Ensure that your QA team or provider goes beyond catching and correcting errors by proactively analyzing clinician performance through data reports. 

    Thriving in the Value-Based Care Era

    Maintaining compliance and clinical competency comes with financial implications. However, home health businesses should move forward with the mindset that improved performance will translate to better financial standing through higher reimbursements.

    While this new era of compliance can be nerve-racking, it is also an opportunity to improve systems and processes. Beyond ensuring internal efficiency, leveraging external support such as tech solutions and an outsourced team can help position your agency on a trajectory toward success. You can never go wrong with a well-designed plan that is carefully and thoughtfully executed.