CMS Finalizes 2020 Home Health Payment Rule and Policy Changes

Last week, the Centers for Medicare and Medicaid Services (CMS) finalized the proposed 2020 Home Health Payment Rule. As members may recall, CMS proposed increasing cuts in home health reimbursement rates from 6.45 percent to 8.01 percent based on the assumption that providers would be upcoding. Last week's final rule reduced that 8.01 percent cut down to 4.36 percent. It is likely that CMS was feeling some pressure due to the bipartisan congressional support for eliminating the cuts in legislation. While the decrease is helpful, LeadingAge NY will continue to advocate for legislation that limits reductions to no more than 2 percent annually and waives homebound rules for certain Medicare beneficiaries. This final rule leaves the Patient-Driven Groupings Model (PDGM) substantially intact. It also provides for:

• A market basket update of 1.5 percent with a -0.2 percent decrease based on the rural add-on;
• Elimination of Requests for Anticipated Payment (RAPs) for new Certified Home Health Agencies (CHHAs), and a complete phase-out for all CHHAs by 2021;
• The requirement to submit a notice of admission within five days of receiving a new patient, starting in 2021. An electronic submission process would be made available by CMS;
• Authorization of therapist assistants to furnish maintenance therapy, in addition to restorative therapy, which is currently allowed;
• A split percentage payment approach under the Home Health Prospective Payment System (HH PPS);
• Implementation of the permanent home infusion therapy benefit in calendar year (CY) 2021, including payment categories, amounts, and required and optional adjustments. It also solicits comments on options to enhance future efforts to improve policies related to coverage of eligible drugs for home infusion therapy; and
• Implementation of the PDGM, an alternate case-mix adjustment methodology with a 30-day unit of payment, mandated by the Bipartisan Budget Act of 2018 (BBA of 2018).

The final rule can be downloaded from the Federal Register here, and the CMS Fact Sheet can be found here.

LeadingAge NY will provide further analysis of the final 2020 Home Health Payment Rule and its most recent revisions.

Contact: Meg Carr Everett, meverett@leadingageny.org, 518-867-8871