On June 26th, CMS released the CY 2025 Home Health Proposed Payment Rule, outlining potential adjustments to Medicare payment rates, Quality Reporting, the Home Health Value-Based Purchasing (HHVBP) Model, and other Medicare policies. We have summarized here the most notable proposed changes and updates:
Payment Update
CMS is proposing a decrease of 4% in the permanent rates. This reduction is slightly mitigated by a 2.5% increase in the Market Basket, factoring in a productivity reduction.
Overall, CMS estimates that Medicare payments to home health agencies in CY 2025 would decrease in the aggregate by 1.7% changing the permanent 30-day base payment rate from $2,038.13 to $2,008.12.
Quality Reporting Program
CMS is proposing to collect 4 additional items and replace 1 item as part of the standardized patient assessment data elements (SPADES) under the social determinants of health (SDOH) beginning for the CY 2027 HH QRP.
- 2 new items of food insecurity
- 1 new item on the living situation
- 1 new item on utilities
- Revise (1) transportation item
CMS is also seeking public comments on four future HH QRP quality measure concepts to guide their development efforts.
- Composite of vaccinations
- Depression
- Pain management
- Substance use disorders
Removing the suspension of OASIS all-payer data collection
CMS is proposing to end the suspension of OASIS all-payer data collection and change the collection start time to the Start of Care (SOC) OASIS timepoint instead of the Discharge OASIS timepoint. The SOC is the first assessment that can be submitted for non-Medicare/non-Medicaid patients:
Voluntary: January 1, 2025
Mandatory: July 1, 2025
During these periods, CMS will use the M0090 Date Assessment Completed from the SOC assessment to identify non-Medicare/non-Medicaid patient assessments.
HHVBP Model
In the 2025 proposed rule, CMS only seeks feedback on potential new value-based purchasing measures for 2027, requesting information at this stage. They are also considering a new Condition of Participation (CoP) focusing on referral acceptance decisions and related policies. They seek input on factors influencing patient acceptance decisions, access to care issues, and any instances where rate changes have impacted patient access.
Therapists on Conducting SOC Assessment
CMS seeks input to assess whether therapists should be allowed to conduct the Start of Care Assessment when both therapy and skilled nursing are ordered. Traditionally, since the implementation of OASIS, only nurses have been allowed to conduct the SOC assessment in such cases.
Understanding the proposed changes provides essential insights to minimize setbacks and maintain operational stability for the upcoming year in home health. Most especially, it helps home health organizations prepare for adjustments in finances and the work required to adapt to the changes. One thing to pay close attention to is ensuring that the new guidelines and updates are accurately reflected in the documentation
