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.
The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service hospital inpatient prospective payment system for fiscal year (FY) 2022. Provisions of the final rule take effect Oct. 1, 2021, unless otherwise noted. Included in the rule are provisions that will:
- Repeal the requirement that hospitals report the median payer-specific negotiated rate for inpatient services by Medicare severity diagnosis-related group (MS-DRG) for Medicare Advantage plans on the Medicare cost report for periods ending on or after Jan. 1, 2021. The CMS is also repealing the market-based MS-DRG relative weight methodology it had planned to implement in FY 2024 and will continue using the existing cost-based methodology.
- Provide hospitals with a neutral score for the FY 2022 Value-based Purchasing (VBP) program due to suppressing many of the measures impacted by the public health emergency (PHE). The CMS also finalized a measure suppression policy for certain measures in the Readmissions and Hospital-acquired Conditions (HAC) Reduction programs impacted by the PHE. Unlike the FY 2022 VBP program, hospitals will be scored for the FY 2022 Readmissions and HAC Reduction programs using the remaining measures.
- Extend the New COVID-19 Treatments Add-on Payment for certain eligible products through the end of the fiscal year in which the PHE ends and provide a one-year extension of the Technology Add-on Payments for 13 technologies that otherwise would be discontinued in FY 2022.
- Provide a net 2.7% increase to the standard operating rate, after budget neutrality, for hospitals that comply with the CMS quality reporting program (QRP) requirements and a 1.4% increase in the federal capital rate. Hospitals that fail to comply with the QRP or electronic health record (EHR) meaningful use requirements are subject to a lower operating rate update.
- Increase the cost outlier threshold by 6.6% from the current $29,064 to $30,988, resulting in fewer cases qualifying for an outlier payment.
- Decrease the Medicare uncompensated care pool by approximately $1.1 billion, resulting in a pool of roughly $7.2 billion that would be distributed using Worksheet S-10 data from FY 2018 cost reports.
- Adopt five new measures in the hospital inpatient QRP, most notably the COVID-19 Vaccination Coverage Among Health Care Personnel (HCP) and adoption of practices to reduce maternal morbidity. These two measures must be reported starting Oct. 1, 2021, and will impact FY 2023 payment determinations.
- Remove three measures from the inpatient QRP beginning with the FY 2026 payment determination:
- Exclusive Breast Milk Feeding (PC-05) (NQF #0480).
- Admit Decision Time to Emergency Department Departure Time for Admitted Patients (ED-2) (NQF # 0497).
- Discharged on Statin Medicaid electronic clinical quality measure (STK-06) (NQF #0439).
- Continue the EHR reporting period of a minimum of any continuous 90-day period for new and returning eligible hospitals for calendar years 2022 and 2023 and increasing it to a minimum of any continuous 180-day period for calendar year 2024.
The CMS had proposed to implement several provisions of the Consolidated Appropriations Act, including its requirement for 1,000 new Medicare-funded medical residency positions over five years; however, due to the number and nature of comments received, the agency will address those provisions in future rulemaking. In addition, the agency had proposed to codify into Medicare regulations some longstanding Medicare organ acquisition payment policies but will also address those regulations in future rulemaking.
The MHA will provide hospitals with an updated impact analysis of the final rule soon. Members with questions should contact Vickie Kunz at the MHA.