On November 1, CMS released the CY 2025 Home Health Payment Final Rule. It includes a permanent adjustment of -1.975% to the base payment rate, which is half the total required adjustment (-3.95%) to counter expected PDGM-related behavior adjustment.
The rule also finalizes a 2.7% payment update for CY 2025 (a $445 million increase), partly offset by a 1.8% overall decrease due to several adjustments, including the -1.975% reduction and recalibrated FDL.
Overall, CMS expects Medicare payments to HHAs to increase by 0.5% ($85 million) compared to CY 2024. Other key updates are outlined below:
Quality Reporting Program (HH QRP) Updates
Starting in 2027, the final rule adds four new standardized assessment items under social determinants of health (SDOH) — covering living situation, food, and utilities — and modifies an existing transportation item.
Additionally, CMS will require all-payer data collection at the start of care, rather than at discharge. Voluntary data collection begins on January 1, 2025, with mandatory collection starting on July 1, 2025.
Crosswalk for Mapping OASIS-D to OASIS-E Data Elements
CMS used the October 2019 3M Home Health Grouper to assign a HIPPS code to each 60-day episode, which required OASIS-D responses. To continue using this system, CMS will need to impute responses for three items that changed in OASIS-E. Additionally, 13 OASIS-E items are no longer required at the follow-up assessment, but CMS can use the most recent SOC or ROC to determine a response without needing imputation.
CMS finalized a crosswalk to address this issue by mapping the OASIS-E items back to the OASIS-D in the final rule.
LUPA Add-on Factor Updates
CMS has finalized the OT LUPA add-on factor at 1.7238, using the same methodology as for SN, PT, and SLP LUPA add-ons. This factor applies when OT is the first skilled visit in a LUPA episode, whether it’s the only or an initial episode in a series. Updates were also made to the SN, PT, and SLP LUPA add-on factors, now set at 1.7200, 1.6225, and 1.6696, respectively, based on recent claims through CY 2023 to better reflect current healthcare practices and costs.
CoP Updates
CMS is finalizing updates to the HHA CoPs to help avoid care delays by ensuring referring entities and prospective patients can choose the most suitable HHA based on care needs. A new standard requires HHAs to create, implement, and review annually a consistent patient acceptance-to-service policy for all referrals.
The policy must address key factors like the patient’s anticipated needs, the HHA’s caseload, staffing levels, and staff skills. This rule doesn’t replace existing policies but is meant to complement them. Additionally, HHAs must publicly provide accurate information about available services and any limitations, updated at least annually or as services change.
HHVBP Updates
Request for Information (RFI) on Future Performance Measure Concepts
This final rule summarizes comments on a response summary for the expanded HHVBP Model’s technical expert panel (TEP) meeting from November 2023. Discussions focused on potential new measures to address gaps, including function measures for activities like bathing and dressing, which are currently outside the Discharge Function measure. CMS may also consider adding the Medicare Spending per Beneficiary measure and exploring measures related to family caregiver status and major injury falls.
Health Equity
CMS provided an update on health equity, reaffirming its commitment to advancing it within the expanded HHVBP Model. CMS will continue gathering input from home health stakeholders and monitoring health equity policies across CMS programs, including proposed payment adjustments in the Hospital and SNF Value-Based Purchasing Programs.
Other updates include the recalibration of PDGM Case-Mix Weights and an update to the home health wage index. Read the full fact sheet on the final rule from CMS here >
