On July 2, 2018, CMS released the 2019 Home Health Proposed Rule. It includes considerable proposed changes to the Home Health Prospective Payment System designed to “strengthen and modernize Medicare, drive value, and focus on individual patient needs rather than volume of care.”
Payment Rate Changes for CY2019
CMS projects that Medicare payments for CY2019 would increase by 2.1%, or $400 million, based on the proposed policies. The rural add-on amount will depend on whether the home health agency is in a frontier area or a high utilization area. In frontier areas, the add-on will increase to 4%, high utilization areas will drop to 2%, and the the remaining will get 3%. LUPA will remain the same.
Patient-Driven Groupings Model (PDGM)
The Bipartisan Budget Act of 2018 requires a change in the unit of payment under the HH PPS, from 60-day episodes of care to 30-day periods of care. The proposed PDGM model would eliminate the use of “therapy thresholds” in determining payment, with the intent of removing current incentives to provide more therapy services than necessary.
An updated version of the Home Health Groupings model (HHGM), the PDGM would be implemented in a budget-neutral manner on January 1, 2020. According to CMS, “The improved structure of this proposed case-mix system would move Medicare towards a more value-based payment system that puts the unique care needs of the patient first while also reducing the administrative burden associated with the HH PPS.”
Home Health Quality Reporting Program (HH QRP)
In the 2019 Home Health Proposed Rule, CMS proposes changes to the HH QRP program. It proposes replacing the current policy for removing previously adopted HH QRP measures with a policy that outlines eight consideration factors for removal of measures. It also proposes removing seven quality measures beginning in the CY2021 HH QRP based upon one of these eight proposed factors. Lastly, it is proposing to update regulations to clarify that only a portion of OASIS data is used to determine whether a home health agency has satisfied the HH QRP reporting requirements for a program year.
According to CMS, the cost impact related to updated data collection processes as a result of the proposed implementation of the PDGM and proposed changes to the HH QRP are estimated to result in a net $60 million in annualized cost savings to home health agencies, or $5,150 in annualized cost savings per home health agency, beginning in CY2020.
Remote Patient Monitoring
CMS is proposing to allow the cost associated with patient monitoring devices to be reported by home health agencies as allowable costs on the Medicare cost report. The purpose of this is to encourage the adoption of emerging technologies and facilitate data sharing for more effective care planning.
Home Infusion Therapy
The 2019 Home Health Proposed Rule includes details on the implementation of home infusion therapy temporary transitional payments as required by the Bipartisan Budget Act of 2018. CMS is seeking comments on elements of the new home infusion therapy benefit category and is proposing standards for home infusion therapy suppliers and accrediting organizations of these suppliers as required by the 21st Century Cures Act.
Reduced Physician Burden
CMS proposes to remove the requirement that the certifying physician estimate how much longer skilled services would be needed during recertification, as this information is already gathered on the patient’s plan of care.
Additionally, CMS proposes to amend current regulations to align with current sub-regulatory guidance to allow use of medical record documentation to support the basis for certification of home health eligibility, consistent with the Bipartisan Budget Act of 2018.
Home Health Value-Based Purchasing Model
CMS proposes to remove two OASIS‑based measures, “Influenza Immunization Received for Current Flu Season” measure and the “Pneumococcal Polysaccharide Vaccine Ever Received” measure from the set of applicable measures. It will replace three OASIS-based measures with two proposed composite measures on total change in self-care and mobility, amend how it calculates the Total Performance Scores by changing the weighting methodology for the OASIS-based, claims-based, and HHCAHPS measures, and rescore the maximum amount of improvement points.
CMS is requesting stakeholder feedback on the possibility of revising the Home Health Conditions of Participation related to interoperability as a way to increase electronic sharing of data by providers.
CMS has published CMS has published an impact assessment tool that lists all home health agencies and the estimated impact that the new payment model would have on each. The estimates are based on a comparison of the new model with the existing model. View PDGM Agency-Level Impacts, Estimated for CY2019 tool here. Additionally, you can view CMS’s Home Health Agency Center for a number of other tools that may prove useful regarding the 2019 Home Health Proposed Rule.
Stay tuned for more information from HEALTHCAREfirst regarding the 2019 Home Health Proposed Rule, including additional blog posts and a complimentary webinar that will detail the key components of the rule.
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