Comments Due Aug. 16 on Medicare Home Health PPS Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released the proposed rule to update the Medicare fee-for-service (FFS) home health (HH) prospective payment system (PPS) effective Jan. 1, 2023. Highlights of the proposal include:

  • A net 6.25% decrease in the national, 30-day standardized payment amount after the estimated 6.9 percentage point cut to achieve budget-neutrality for the Patient-Driven Groupings Model on a prospective basis. The proposed payment rate is $1,904.76, down from the current $2,031.64 for HHs that comply with HH quality reporting program (QRP) requirements.
  • An increase in the fixed-dollar loss ratio from the current 0.40 to 0.44.
  • A permanent 5% cap on wage index decreases to mitigate significant payment reductions from wage index changes.
  • Comment solicitation regarding the data collection on the use of remote services at the individual beneficiary level, which would allow the CMS to analyze the characteristics of the beneficiaries using remote services and potential for identifying social determinants of health that impact use of remote services.
  • Ending the suspension of data submission for non-Medicare/non-Medicaid patients. HH agencies would be required to submit all-payer OASIS data for purposes of the HH QRP beginning with the 2025 program year.
  • Changes to the Expanded HH value-based purchasing (VBP) model, including definitions for the baseline and model year, changing the baseline year from 2019 to 2022 for existing HH agencies and modifying the model year from 2019 to 2022 beginning in 2023.
  • Seeking feedback on development of health equity measures for the HH QRP and potential future application of health equity in the Expanded HH VBP model’s scoring and payment methodologies.

The MHA will provide members with an estimated impact analysis within the next few weeks and share draft comments prior to the Aug. 16 deadline. The MHA encourages members with HH operations to review the impact of the proposed rule on their operations and submit comments to the CMS. Members that have not received impact analyses in the past for affiliated, free-standing HH agencies are encouraged to provide the agency’s CMS certification number (also known as Medicare provider number), agency name, and federal information processing standards code to receive an estimated impact analysis in the future. Members are encouraged to forward this information and questions to Vickie Kunz at the MHA.

Comments Due Aug. 27 on Home Health Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system for home health (HH) agencies effective Jan. 1, 2022. Key aspects of the proposal include:

  • Expanding the HH value-based purchasing model nationally to replace the pilot that began in nine states (AZ, FL, IA, MD, MA, NE, NC, TN, WA) in 2016.
  • Increasing the national, standardized 30-day HH payment rate by 5.9% from $1,901.12 to $2,013.43 for HH agencies that submit the required quality data.
  • Recalibrating the Patient-driven Groupings Model (PDGM) case-mix weights for the 432 payment groups using 2020 data.
  • Updating the HH quality reporting program to:
    • Remove the Outcome and Assessment Information Set (OASIS)-based Drug Education on All Medications Provided to Patient/Caregiver During All Episodes of Care measure.
    • Replace two claims-based measures, the Acute Care Hospitalization During the First 60 Days of Home Health (NQF #0171) measure and Emergency Department Use without Hospitalization During the First 60 days of Home Health (NQF #0173), with one claims-based measure, Home Health Within Stay Potentially Preventable Hospitalization.
  • Modifying HH aide supervision requirements to make permanent the regulatory blanket waivers related to HH aide supervision that were issued during the COVID-19 pandemic.
  • Implementing a provision of the Consolidated Appropriations Act that would allow occupational therapists to perform the initial and comprehensive patient assessment.
  • Continuing the 4.36% behavioral adjustment reduction to the standardized 30-day payment rate implemented in 2020 when the new PDGM was adopted.
  • Consistent with other recent proposed rules, the CMS included two requests for information:
    • The use of fast healthcare interoperability resources in support of digital quality measurement in quality reporting programs.
    • Closing the health equity gap on ways to attain health equity for all patients.

Members are encouraged to review the proposed rule and submit comments to the CMS by Aug. 27. The MHA will provide members with an estimated impact analysis within the next few weeks. Those with questions should contact Vickie Kunz at the MHA.