Last June 28, the Centers for Medicare & Medicaid Services (CMS) issued the Home Health Prospective Payment System (HH PPS) proposed rule for 2022, which re-focuses the shift from paying for home health services based on volume to a system that incentivizes higher quality care.
One of the most significant and noteworthy changes is the nationwide expansion of the home health value-based purchasing (HHVBP) model. Other changes are related to the Patient-Driven Groupings Model (PDGM), Low-Utilization Payment Adjustments (LUPAs), Conditions of Participation (CoPs), Quality Reporting Program, and COVID-19 blanket waivers.
Here are the key takeaways from the proposed rule in summary:
Increase in Medicare Payments for Home Health
CMS proposed to increase Medicare payments to home health agencies by 1.7% next year, which equates to an estimated $310 million growth.
HHVBP National Expansion
CMS is proposing to expand HHVBP nationwide beginning January 1, 2022 from the nine (9) current participating states (i.e. Massachusetts, Maryland, North Carolina, Florida, Washington, Arizona, Iowa, Nebraska, and Tennessee).
There was also a proposal to end the original HHVBP Model one year early for the agencies in the current participating states. This means that CMS would not use CY 2020 data to make payment adjustments for next year. Furthermore, if realized in the final rule, the first performance year of the expanded HHVBP Model would be CY 2022, using quality performance data from that year to calculate payment adjustments under the expanded model in CY 2024.
CMS stated that it will not be making any changes to the 4.36% behavioral adjustment in PDGM and that it plans on delaying any corrections until the COVID-19 Public Health Emergency (PHE) is over and more reliable data is available..
On the other hand, the proposed rule mentioned that CMS is conducting ‘preliminary analyses’ of the data from the first year of PDGM, specifically data pertaining to admission source, timing, clinical grouping, functional-impairment level, and more. Insights into how differences between assumed and actual behavior changes are being analyzed were also discussed.
New OT Flexibility and corresponding LUPA adjustment
CMS will implement regulatory modifications to allow an Occupational Therapist (OT) to complete the initial assessment and SOC comprehensive assessment for Medicare patients when OT is ordered with speech-language pathology (SLP) and/or physical therapy (PT) but where skilled nursing is not initially part of the plan of care.
This will not change nor pose a conflict to the statutory requirements for establishing Medicare program eligibility. Only the need for skilled nursing, PT and/or SLP services continue to establish eligibility for Medicare home health benefit.
Consequently, when OTs are able to conduct assessments and certify for home health services, CMS is also proposing an add-on factor to adjust for that first skilled OT visit in LUPA periods.
Quality Reporting Program
CMS is also proposing some modifications to the Home Health Quality Reporting Program such as the removal of certain measures that increase the burden on providers and adjustments for home infusion therapy. Specifically, they will be removing the OASIS-based “Drug Education of All Medications Provided to Patient/Caregiver During All Episodes of Care” measure because its performance is high enough among home health care agencies that meaningful distinctions between performances can no longer be made.
Conditions of Participation (CoP)
CMS is proposing to make permanent selected regulatory blanket waivers related to home health aide supervision and the use of telecommunication that were issued during the COVID-19 public health emergency (PHE). CMS believes that allowing telecommunication flexibility for the required 14-day on-site supervisory visit by home health aides is an important component in assessing the quality of care and services and to ensure that they meet the patient’s needs.
Keeping the Stability in Spite of the Changes
Aside from additional flexibilities and incentives, other changes in the CMS proposed rule were more measured and subtle, most likely to allow agencies to recuperate from challenges related to the COVID-19 PHE.
On the other hand, the changes in the proposed rule will most probably disrupt established workflows so agencies can integrate the new flexibilities and comply with new standards, or at least to pursue incentives. To stay on top of all changes, it would help to work with a team who is knowledgeable of the technicalities of compliance standards. The right partner leverages data and employs the right tools to help you establish benchmarks that provide a bird’s eye view of your processes, so you can get back to the rhythm and keep consistent streamlined workflows. Simply put, find a partner that can help provide stability in the midst of the ever-changing home health landscape.