As we approach 2025, the home healthcare industry faces significant changes in payments, compliance, and documentation requirements. This year will likely mark a pivotal point for the industry as it adapts to new challenges and opportunities. We have prepared a quick summary of the key changes agencies should be aware of as 2025 nears.
Payment Adjustment
CMS projects a 0.5% increase in aggregate Medicare payments to Home Health Agencies (HHAs) for CY 2025, translating to an additional $85 million. This reflects a 2.7% base payment update ($445 million), offset by a 1.8% reduction. The reduction includes a -1.975% base rate adjustment to address PDGM-related behavioral changes and a recalibrated FDL.
OASIS All-Payer Data Collection
Beginning in 2025, HHAs will be required to complete and submit OASIS data for Quality Reporting for all patients, regardless of payer. CMS mandates the collection of all-payer data at the start of care rather than at discharge. This data will significantly impact both star ratings and value-based purchasing outcome calculations.
- Voluntary Reporting: Starts January 1, 2025
For non-Medicare/non-Medicaid, submitting OASIS data is voluntary for SOC with M0090 dates between January 1 and June 30, 2025. If an agency begins OASIS data collection for these patients, they are not required to complete subsequent assessments (e.g., resumption of care, recertification, transfer, or discharge), even for assessments conducted on or after July 1, 2025. - Mandatory Reporting: Starts July 1, 2025
Starting July 1, 2025, OASIS data collection and submission to iQIES are required for all patients regardless of pay source. This includes the start-of-care (SOC) assessment and all subsequent assessments (e.g., resumption of care, recertification, follow-up, transfer, discharge, and death at home).
2025 HHVBP Updates
In 2025, payments for claims with a service date in that year will be adjusted according to your 2023 HHVBP data. This adjustment, based on your final 2023 performance percentage, may have either a positive or negative impact on your payments.
New Discharge Function Score
Effective January 2025, the Total Normalized Composite (TNC) scores for self-care and mobility under HHVBP will be replaced by the Discharge Function Score which will be based on the GG items.
When clinicians complete an OASIS at Start of Care or Resumption of Care, the responses to the GG items are used to calculate the patient’s “expected discharge status” based on these initial responses. At discharge, the GG item responses on the Discharge OASIS are compared to the Expected Discharge Status. If the Observed Discharge Status matches or exceeds the Expected Discharge Status, the agency receives a positive score.
Changes from OASIS-E to OASIS-E1
- New skip patterns (M0102)
- Removal of M0110 (Episode Timing) and M2200 (Therapy Need)
- Removal of the GG0130 and GG0170 Discharge Goals from the SOC/ROC time points.
- Revised instructions for answering D0105 (Patient Health Questionnaire)
- Addition of the new item O0350 – COVID-19 Vaccine to the Transfer, Discharge, and Death At Home time points.
Our team at Qavalo has completed comprehensive training and orientation on the 2025 updates and their impact. This included refresher sessions on responding to GG items, conducting proper functional assessments, and accurately documenting discharge OASIS to reflect patient status and progress. Additionally, OASIS-E1 training was provided to ensure familiarity with the changes in OASIS items, assessments, and documentation. For further insights on the changes for 2025, you may check out our other related articles on specific topics:
Key Takeaways: CY 2025 Home Health Payment Final Rule
Key Updates from the CY 2025 Home Health Proposed Payment Rule
Proposed Rule: OASIS Reporting Required for All Payers in 2025
October 2024 IPRs Out Now; HHVBP Preparations for 2025
Explaining the Impact of GG Items with the New Discharge Function Score
Shifting from G to GG items in QRP and VBP
6 Tips for Completing a Discharge OASIS
Out Now: OASIS-E1 Draft Guidance Manual and Time Point Versions
