On Tuesday, July 25, 2017, CMS issued the CY 2018 Home Health Proposed Rule. Effective for home health episodes of care ending on or after January 1, 2018, the rule updates the Home Health Prospective Payment Systems (HH PPS) payment rates including the national, standardized 60-day episode payment rates, the national per-visit rates, and the non-routine medical supply (NRS) conversion factor. The overall payment rate for home health care will be reduced 0.4%, resulting in $80 million less in payments to home health agencies for CY2018.
Additionally, the 2018 Home Health Proposed Rule includes:
Case-Mix Adjustment Methodology Refinements for CY2019
Major changes have been proposed to the Medicare payment system. Effective January 1, 2019, proposed case-mix methodology refinements, known as the home health groupings model (HHGM), include a change in the unit of payment from 60-day episodes to 30-day periods and more heavily rely on clinical characteristics along with other patient information to place 30-day periods into meaningful payment categories. The HHGM also eliminates therapy service use thresholds that are currently used to case-mix adjust payments under the HH PPS.
CMS is soliciting comments on these proposed payment methodology refinements.
Home Health Quality Reporting
Proposed changes to the Home Health Quality Reporting Program (HHQRP) include the adoption of three measures for payment determination for calendar year 2020 to meet the requirements of the IMPACT Act. The three proposed measures are calculated using the following OASIS data:
- Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury
- Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF # 0674)
- Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631)
Additionally, CMS is proposing new, standardized data elements in four other categories: functional status; cognitive function and mental status; special services, treatments and interventions; and impairment.
Beginning on January 1, 2019, CMS also proposes removing or modifying 35 current OASIS items because they are proposing to no longer collect them. These changes can be found at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/HHQIQualityMeasures.html.
Home Health Value-Based Purchasing (HHVBP)
CMS proposes to refine the Home Health Value-Based Purchasing (HHVBP) Model, revising the definition of “applicable measure” to specify that home health agencies in the HHVBP would have to submit a minimum of 40 completed HHCAHPS surveys for purposes of receiving a performance score for any of the HHCAHPS measures. The plan would be to remove the OASIS-based measure and Drug Education on All Medications Provided to Patient/Caregiver during all Episodes of Care from the set of applicable measures. CMS is soliciting public comments on composite quality measures for future consideration.
Want to learn more about the 2018 Home Health Proposed Rule? HEALTHCAREfirst hosted a FREE webinar with Deanna Loftus, Director or Regulatory Compliance, and home health regulatory expert Mary St. Pierre, RN, BSN, MGA, on August 24, 2017 where we explained the proposed rule and the impact that it could have on your home health agency. Click here to access the webinar recording.