On July 1, 2018, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule with several changes facing home health care providers next year and beyond. Below is a summary of those changes, courtesy of our colleagues National Association for Home Care & Hospice (NAHC), and resources for providers to submit comments to the Centers for Medicare & Medicaid Services.
HCAF submitted comments to CMS on Friday, August 31, 2018 in response to the proposed policy. Click here to read the comments.
Please direct questions to Kyle Simon, HCAF Director of Government Affairs and Communications, at email@example.com or call (202) 830-4080.
The 2019 proposed payment rates increase by 2.1% ($400 million)
The 2019 rural add-on amount depends on whether the home health agency is in a frontier area or a high utilization area –– 234 counties are considered frontier where the add-on will increase to 4%; 510 counties are high utilization where the add-on will drop to 2%; the remaining 1,162 counties will get 3% (High utilization counties in Florida include Bradford, Columbia, De Soto, Dixie, Glades, Hamilton, Hardee, Hendry, Holmes, Lafayette, Levy, Liberty, Okeechobee, Putnam, Suwannee, and Union)
Outlier eligibility will be slightly tightened with the Fixed Dollar Loss ration dropping to 0.51% from 0.55%
Low Utilization Payment Adjustment (LUPA) stays the same
CMS proposes a new payment model that looks a lot like the previously-proposed and withdrawn Home Health Groupings Model (HHGM):
Transition to 30-day payment units;
Therapy thresholds gone;
Case mix adjustment model with 216 categories using measures such as “early” or “late” time period, institutional discharge or community admission, three functional levels, and a comorbidity adjustment;
-6.42% behavioral adjustment to base rates for diagnosis coding and visit volume changes;
Budget-neutral rate setting except for the behavioral adjustment (the proposed 30-day payment unit increases to $1,873.91 from the 2017 HHGM proposal at just over $1,600);
Combined care and non-routine medical supplies;
30-day LUPA ranging from two to seven visits depending on case mix category;
Possible end to Request for Anticipated Payment (RAP);
New home infusion therapy benefit, as created by the 21st Century Cures Act;
Elimination of requirement that the certifying physician specifically state how much longer care would be needed;
Permit the incorporation of home health agency records into the physician record, including through the use of the Plan of Care;
Home Health Value-Based Purchasing demonstration refinements; and,
The 600-page proposal includes refinements to the Home Health Value-Based Purchasing Demonstration and OASIS. If implemented as proposed, PDGM would go into effect on or after January 1, 2020. CMS is accepting comments until 5:00 p.m. ET on August 31, 2018.
When commenting, please reference the document identifier or OMB control number CMS-1689-P. To be assured consideration, comments and recommendations must be submitted in any one of the following ways:
Electronically. You may send your comments electronically here.
By regular mail. You may mail written comments to the following address: Centers for Medicare & Medicaid Services, Office of Strategic Operations and Regulatory Affairs, Division of Regulations Development, Attention: Document Identifier/OMB Control Number CMS-1689-P, Room C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.
To obtain copies of a supporting statement and any related forms for the proposed collection(s) summarized in this notice, you may make your request using one of following: