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CMS Finalizes 2021 Home Health Payment Rule

On Oct. 29th, the Centers for Medicare and Medicaid Services (CMS) issued its final home health payment rule for 2021. The final rule is available here, and a CMS fact sheet is here.

Some Main Points

Medicare payments will increase by an estimated 1.9 percent, or $390 million, down from CMS’s proposed rule, which estimated a 2.6 percent increase (or $540 million). This change was a result of CMS applying more recent data in the market basket index.

According to CMS, the final rule includes a 2 percent home health payment update percentage ($410 million increase) and a 0.1 percent decrease in payments due to reductions in the rural add-on percentages (a $20 million decrease).

CMS notes that the first quarter 2020 forecast used for its initially proposed market basket increase was developed prior to the economic impacts of the COVID-19 public health emergency (PHE). This update (2 percent) for 2021, lower relative to the proposed rule (at 2.7 percent), is primarily driven by slower anticipated compensation growth for both health-related and other occupations as labor markets are expected to be significantly impacted during the recession that started in February 2020 and throughout the anticipated recovery.

Other Payment, Program Changes

The rule adopts revised delineations for the wage index as well as the originally proposed 5 percent cap on wage index decreases. It also finalizes the Medicare home infusion therapy supplier enrollment and services payment rates, which exclude home infusion therapy services from home health services.

PDGM

The rule does not make any major changes to the Patient-Driven Groupings Model (PDGM). However, it does maintain the status quo by keeping the controversial behavioral assumption adjustment built into the PDGM payment structure. LeadingAge NY will continue to advocate for legislation to withdraw this language from the model.

Telehealth

The rule includes telehealth provisions reflecting language that CMS implemented during the PHE, but without direct payment support for telehealth. CMS will allow use of telecommunications technologies under the Medicare home health benefit as long as the service is included on the plan of care, does not substitute for an in-person home visit, and it still cannot be considered a visit for the purpose of patient eligibility or payment.

As members know, actual reimbursement for home health telehealth remains a priority. The PHE enabled many provider types to engage in reimbursement of telehealth, while home health was excluded. We urge members to take action and support recently introduced legislation to allow adequate Medicare payment for telehealth services delivered by home health agencies. Please reach out to your members of Congress today via LeadingAge National’s action alert here.

Contact: Meg Everett, meverett@leadingageny.org, 518-929-9342