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Home-based care industry insiders are encouraged by the steps the Centers for Medicare & Medicaid Services (CMS) is taking in releasing its first ever home- and community-based services (HCBS) quality measures.
While it’s still early in the process, experts believe now is the time for providers to begin talks with state agencies in order to be better prepared for when the quality measures take effect.
CMS released the HCBS quality measures last week to promote “consistent quality measurement within and across state Medicaid HCBS programs.”
Historically, HCBS providers have not been as regulated across the country, at least compared to home health agencies and Medicare-reimbursed businesses. The new HCBS measures proposed by CMS sets up standards across the board, particularly among Medicaid-focused HCBS providers.
“It is a highly positive thing to have happened,” National Association for Home Care & Hospice (NAHC) President William A. Dombi told Home Health Care News. “It’s welcomed news that they’re looking to standardize measures. It’s also positive that those measures should help bring some accountability from the states, to both providers as well as consumers of the services.”
Currently, states “are not equal with each other” in terms of what programs they have or what level of access they have, Dombi noted.
Other advocates expressed similar sentiments.
Deb Oberman, one of the leaders of the Partnership for Medicaid Home-Based Care (PMHC), told HHCN in an email that her organization looks forward to working with states in their efforts to ultimately “adopt, amend and implement quality standards to effect positive change.” Oberman is also senior vice president of government relations at Help at Home, a Chicago-based home care provider.
“At this point, the measures provide direction on future efforts by states to adopt consistent quality of care standards that ultimately serve to strengthen the role and overall reputation of Medicaid-funded home care services,” Oberman said. “These represent a good first step – an acknowledgement that quality is a key element of a long-sustaining, well-regarded industry.”
Medicaid HCBS has been growing for years, Dombi said. Services have been around for three decades as an alternative to nursing homes, but it has taken this long for CMS to implement standards across the board.
The proposed measures are built around three pillars: access, rebalancing HCBS spend versus institutional care spend and community integration. For now, the measures are voluntary, but Dombi expects that to change in the near future.
“I think their game plan is to ultimately make it mandatory,” Dombi said. “Do we expect it to be there in some mandatory fashion? From our experience, it’s going to depend upon who on the federal side is running Medicaid. Different administrations have taken a different role in how and what kind of mandates they put on states.”
Oberman echoed Dombi’s stance, adding that CMS will likely implement the measures on a mandatory basis along the lines of other industry quality measures like Healthcare Effectiveness Data and Information Set (HEDIS) and Star ratings.
Others in the industry, such as LeadingAge’s director of Medicaid and HCBS policy, Meredith Chillemi, believe the measures will go a long way for promoting equity in the space.
“Every American, no matter who they are or where they come from, has the right to access services and to make a fully-informed decision when choosing the services that matter to them,” Chillemi said in a statement. “CMS introduction of the HCBS quality measure set is a step toward ensuring consumers have that information and can fully participate in creating a service plan that meets their needs and goals.”
What home care agencies should do now
While most experts are optimistic about what this means for the home care industry, there is still plenty of work to be done and details to iron through.
“I do think this will help bring some uniformity, relative to access, quality and patient outcomes,” Dombi said. “All of that may be pollyannaish, because they’re setting these voluntary standards to start with, but this was an absolutely essential step that needed to be taken.”
Over the next few weeks, Dombi said NAHC will be talking with home care agencies affected by the new measures and will generally strike a positive tone. Still, he did say that he won’t shy away from the costs that could come with these changes.
“It’s a cost for the state as well as for the Medicaid providers to manage this,” he said. “We need to see a corresponding burden relief with some financial support for what this is going to entail. Medicaid is not a very good payer to begin with, so adding any paperwork burden to it — even if it brings value to an individual provider — is going to be on the shoulders of providers.”
These quality measures have been in development for a long time, Oberman said. PMHC will continue to encourage the development of more quantitative measures related to service initiation.
How the measures will affect Help at Home, Oberman said, is yet to be determined.
Given how these are structured, Help at Home’s perspective would mirror PMHC’s, she said.
“We won’t really know [the] impact until the states have adopted and refined their own particular approach,” she explained.
While the measures are still new, Dombi said home care agencies should familiarize themselves with the direction they initiate and engage with their states on how everything works.
“If they don’t have that connection now through their state association or otherwise, it’s time to start making sure they build it,” Dombi said.
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