CMS has published the proposed update for Calendar Year (CY) 2020 for Home Health Agencies. It looks like CMS is aiming for a more streamlined, modernized and patient-centered home health service line. In accordance with regulatory requirements, Home Health agencies will benefit from an increased reimbursement rate. Changes include who can perform maintenance therapy and the content of a home health plan. To reduce the burden on providers, and consistent with ongoing refinements to best capture of data, CMS proposes revisions to the Home Health Quality Reporting metrics as well. Many of the new changes demonstrate a sustained effort to make data gathering consistent among and between post-acute healthcare providers. Click here to read the details of the upcoming changes.
- Home Health Prospective Payment Updates
- Home Health Payment Increase
- In calendar year 2020, CMS is proposing an aggregate increase of 1.3% over CY19 rates. The rule also proposes the implementation of the Patient Driven Groupings Model (PDGM) for home health periods of care beginning on or after January 1, 2020, as were finalized in the CY19 Home Health Rules. Consistent with other post-acute care venues, this change will focus more on the patient’s clinical condition as opposed to an emphasis on the volume of services provided. In addition to better aligning services with patient care needs, the revised model reflects the change to a 30-day episode of care for payment as opposed to the current 60-day episode of care payment period.
- These rules also propose the continued use of inpatient hospital wage index figures for Home Health Agency Payment wage indexes. The proposed rules speak to maintaining the current methodology for high cost outlier calculation. No rate change is proposed for those 60-day episodes that bridge the implementation date of the PGDM (currently 0.51); and a fixed dollar loss ratio amount of 0.63 is proposed for the newly implemented 30-day episode of care cases.
- Split Percentage Payments
- CMS is proposing to phase out the split percentage payments for currently enrolled Home Health providers through a reduced split billing percentage. The percentage is reduced to 20% from the current 60% (or 50%, depending on new or subsequent periods of care). This action reduces burden on providers who are currently required to submit a Request for Anticipated Payment (RAP) before each episode of care period. CMS is further proposing that the split percentage payment be fully eliminated for all providers in CY2021. To provide notification for each beneficiary of Home Health Care, providers will be required to submit a Notice of Admission. CMS believes the phase-in period will allow providers time to adjust current practices in advance of the CY2021 elimination of split percentage payments.
- Home Health Payment Increase
- Home Health Regulatory Updates
- Maintenance Therapy
- Within this proposed rule, CMS is allowing therapist assistants to perform maintenance therapy activities that were previously impermissible. This proposed change to 409.44(c)(2)(iii) is consistent with other post-acute care venues, such as skilled nursing facilities, permitting therapist assistants to perform maintenance therapy. This proposed rule does not eliminate the need for the plan of care to be developed and overseen by a qualified therapist.
- Home Health Plan Content
- CMS is proposing regulatory changes to § 409.43 related to the Home Health Plan of Care. Specially, CMS is proposing revised language to obtain coverage. The following content must be included within the plan of care:
- Specification of the necessary services to meet the patient needs maintained within the plan of care; and
- Identification of disciplines caring for the patient, including frequency and duration.
- CMS is proposing regulatory changes to § 409.43 related to the Home Health Plan of Care. Specially, CMS is proposing revised language to obtain coverage. The following content must be included within the plan of care:
- Maintenance Therapy
- Home Health Value Based Purchasing
- CMS is proposing to publicly report the Total Performance Score (TPS) and TPS percentile ranking from Performance Year 5 of the Value Based Purchasing Model. This reporting would include the Home Health providers that qualified for payment adjustments in CY2020 from the nine model states.
- Quality Reporting Program
- CMS has proposed removals, additions, and modifications within the Home Health Quality Reporting Program (HH QRP).
- CMS has proposed two new quality measures for CY2020:
- Transfer of Health Information to Provider – Post-Acute Care; and
- Transfer of Health Information to Patient- Post-Acute Care.
- CMS has proposed the removal of the following quality measure in CY 2022:
- Improvement in Pain Interfering with Activity Measure.
- CMS is also proposing that Home Health Agencies report standardized patient assessment data elements (SPADEs) beginning with the CY2022 HHQRP that assess the following:
- Cognitive function and mental status;
- Special Services;
- Treatments and Interventions;
- Medical Conditions and Comorbidities;
- Impairments; and
- Social Determinants of Health (race, ethnicity, preferred language, interpreter services, health literacy, transportation and social isolation).
Lastly, CMS is proposing to remove Question 10 from the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS). This question pertains to discussions surrounding pain; its proposed removal is to avoid any unintended inferences which may arise from such inquiries within the surveys.
The above standardization is consistent with the implementation of SPADES and new quality measurements within other post-acute venues, such as long term acute care hospitals (LTCHs), inpatient rehabilitation facilities (IRFs), and skilled nursing facilities (SNFs).
- Home Infusion TherapyWithin the CY2020 rule, CMS is proposing to update temporary transitional payments as finalized within the CY19 rules. The update will be in accordance with the CY2020 Physician Fee Schedule which has not yet been published.To permit providers time to make necessary changes to operational systems, within the proposed rule CMS recommends the continued use of the three payment categories employed within the temporary payment structure to the permanent payments which will begin in CY2021. Under the temporary structure, there are three infusion drug groupings, with each category having an assigned single unit of payment amount. The above proposal would maintain consistency between the structure noted within the temporary payments and those which will be part of the permanent payments to begin in CY2021.One additional change proposed includes the use of the Geographic Adjustment Factor (GAF) instead of the Geographic Practice Cost Indices (GPCI) for home infusion therapy payment adjustments. This recommendation is believed to be the best avenue to update for Home Health providers. It will be implemented in CY2021.
Conclusion
Advis is a national expert in post-acute care services. Advis can assist providers in submitting comments under the proposed new rules; help determine how the proposed new rules may impact your facility; and/or help in exploring interest in establishing a post-acute care venue beneficial to your organization.
Please be advised, the deadline for submitting comments under the proposed rules is September 9, 2019.
