Medicare Home Health 2021 Final Rule at a Glance

Thoughtware Alert Published: Nov 05, 2020
Stethoscope and laptop

CMS issued the 2021 Medicare Home Health Final Rule on October 29, 2020. The key changes affecting home health (HH) agencies are summarized below.

Payment Rates

CMS has estimated the provisions of the final rule will increase HH payments by an overall $390 million or 1.9 percent for calendar-year (CY) 2021. This increase reflects a 2.0 percent HH payment update with a 0.1 percent rural add-on reduction required by the Bipartisan Budget Act of 2018 for CY 2021. These changes result in a national standardized 30-day payment rate increase from $1,864.03 in CY 2020 to $1,901.12 in CY 2021. Agencies that do not submit required quality data will continue to see a 2 percent reduction from these rates.

The rule also includes adoption of the Office of Management and Budget (OMB) statistical area delineations and places a cap on wage index decreases to 5 percent for CY 2021. No structural changes were made to the Patient-Driven Groupings Model (PDGM) payment model that was implemented in 2020. Despite strong advocacy efforts by the industry, CMS rejected pleas to reduce or remove the behavioral adjustment that is currently built into the PDGM payment structure due to a lack of data to determine whether its budget neutrality obligation was met in 2020.

The 2021 Medicare HH payment rates will be available soon on bkd.com.

No-Pay RAPs

CMS upheld its policy to require no-pay Requests for Anticipated Payment (RAP) effective for 2021 billing periods. This policy requires no-pay RAPs to be billed within five calendar days from the beginning of the billing period to avoid a late submission payment penalty.

Use of Telecommunication Technology

The rule finalized provisions that remote patient monitoring or other services furnished via telecommunication technology must be included on the plan of care (POC) and do not replace a home visit ordered on the POC, nor can they replace a visit for determining eligibility or payment. The rule also clarified that audio-only technology may continue to be used to furnish skilled HH services.

Home Infusion Therapy Services

Medicare enrollment requirements for home infusion therapy suppliers are set forth in the final rule as well as an update to home infusion therapy service payment rates for CY 2021 using the 2021 Physician Fee Schedule amounts. Furthermore, a decision was reached as part of the rule to exclude from the HH benefit services that are covered under the home infusion therapy services benefit.

Care Planning for Medicare HH Services

CMS responded to comments received on the May 20, 2020, COVID-19 interim final rule (IFC) regarding the provisions related to allowing nurse practitioners, certified nurse specialists, and physician assistants to certify and write orders in accordance with state laws. CMS is revising sections of the regulations to reflect these changes.

HH Value-Based Purchasing (HHVBP) Model

As outlined in the IFC, CMS granted alignment of HHVBP Model data submission requirements with exceptions or extensions granted for the purpose of the HH Quality Reporting Program and granted exceptions to the New Measures data reporting requirements during the COVID-19 public health emergency. 

HH agencies are encouraged to review the final rule and evaluate effects on their individual agencies. 

If you have questions about the final rule or would like a deeper analysis of your agency, contact your BKD Trusted Advisor™ or submit the Contact Us form below.

This information is only valid as of the date of this publication and is subject to change. The content was presented for illustrative purposes and your information only. Applying this information to your situation requires careful consideration of facts, circumstances, and timing of requirements. Consult your BKD advisor or legal counsel to apply to your unique situation and circumstances.

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