Thoughtware

Article 10/08/2018

CMS Issues Proposed Home Health Rule for 2019

Presenters/Authors
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The Centers for Medicare & Medicaid Services (CMS) recently issued the 2019 proposed home health rule. This rule includes changes to payment rates and reporting of remote patient monitoring costs, information on a new home infusion therapy benefit, revisions to the Home Health Quality Reporting Program (HH QRP) and Home Health Value-Based Purchasing (HHVBP) and the creation of the Patient-Driven Groupings Model (PDGM).

CMS proposed a 2.1 percent increase for the overall home health payment rate; however, this rate will decrease by 2 percent for agencies that don’t submit required quality data. While the Low-Utilization Payment Adjustment (LUPA) remains the same, outlier payments were constricted marginally.

In observance of the new rural add-on payment requirements set by the Bipartisan Budget Act of 2018, the proposed rule suggests changes to rural areas and classifies them into three categories: “high utilization,” “low population density” and “all other.” The rural add-on payment percentages proposed for 2019 are listed below.

The Rural Add-On Payment Percentages Proposed for 2019 Table

A requirement set by the 21st Century Cures Act included implementing a home infusion therapy benefit, which also is included in the proposed rule. The proposed benefit would cover nursing, patient training and education and monitoring services associated with administering infusion drugs in a patient’s home. Full implementation of the benefit would start in 2021 with a transition period beginning in 2019.

CMS also proposed a provision to permit remote patient monitoring expenses as an all-allowable administrative cost on the Medicare cost report. This would be significant for agencies using such services, as it would allow the costs to be factored into the Medicare allowable costs per visit. In addition, CMS proposed defining remote patient monitoring as “the collection of physiologic data (for example, ECG, blood pressure, glucose monitoring, etc.) digitally stored and/or transmitted by the patient and/or caregiver to the home health agency.”

Regarding certifying and recertifying patient eligibility, CMS proposed to eliminate the current requirement that a certifying physician estimate how much longer skilled services are needed when recertifying a patient for continued home health care. Medical record documentation from home health agencies was also proposed for use in supporting the basis for certification and/or recertification of home health eligibility, if requirements are met.

Changes to the HH QRP and HHVBP were proposed as well. Proposed HH QRP modifications include adopting eight measure-removal factors and removing seven quality measures in 2021. Proposed changes to HHVBP include adding and removing current measures, revising weighting methodology for measures and rescoring the maximum number of improvement points.

The final ruling also includes information on the new PDGM payment model.

Home health agencies should review the final rule and evaluate the potential effect(s) it may have on their organizations.

For further information, contact Eimee or your trusted BKD advisor.