Home Health Prospective Payment System Final Rule for Calendar Year 2015
The Centers for Medicare and Medicaid Services (CMS) filed the final Calendar Year (CY) 2015 Home Health Prospective Payment System (HH PPS) rule on Oct. 30. It will be published in the Federal Register on Nov. 6. LeadingAge NY published an analysis of the proposed rule earlier this year.
Highlights from CMS Fact Sheet on the final HH PPS
According to the Fact Sheet, CMS is proposing measures that are projected to reduce Medicare payments to home health agencies by 0.30 percent, or $60 million. The decrease reflects the combined effects of the 2.1 percent home health payment update percentage ($390 million increase) and the second year of the four-year phase-in of the rebasing adjustments to the national standardized 60-day episode payment rate, the national per-visit payment rates, and a 2.82 percent reduction in the Non-Routine medical Supplies (NRS) conversion factor (a 2.4 percent or $450 million decrease). Under the final rule, the national standardized 60-day payment rate will be reduced by $80.95 in CY 2015, resulting in a payment of $2,961.38.
Face to Face (F2F) encounter requirement - CMS has finalized three changes to the face-to-face encounter requirements for episodes beginning on or after Jan. 1, 2015. The first includes the elimination of the narrative requirement currently in regulation. Second, the rule provides that when a HHA claim is denied, the corresponding physician claim for certifying/re-certifying patient eligibility for Medicare-covered home health services is also considered non-covered because there is no longer a corresponding claim for Medicare-covered home health services. Third, the rule provides that a face-to-face encounter is required for certifications, rather than initial episodes, with "certification" (as opposed to "recertification") defined as any time a new start of care assessment is completed to initiate care.
Therapy Reassessments - CMS has finalized the elimination of the 13th and 19th visit reassessment requirements. For episodes beginning on or after Jan. 1, 2015, at least every 30 calendar days a qualified therapist (instead of an assistant) must provide the needed therapy service and functionally reassess the patient.
Rate-Setting Changes -
Recalibration of the HH PPS case-mix weights - CMS is recalibrating the HH PPS case-mix weights using CY 2013 home health claims data to ensure that the case-mix weights reflect the most current utilization and resource data available.
Core Based Statistical Area (CBSA) changes for the HH Wage Index – As we previously reported, the Office of Management and Budget issued a bulletin in Feb. 2013 that had significant changes related to delineation of Metropolitan Statistical Areas, Micropolitan Statistical Areas, and Combined Statistical Areas, and guidance on uses of the delineation of these areas. CMS finalized the changes to the wage index based on the revised CBSA delineations.
Home Health Payment Update Percentage- The CY 2015 home health market basket (2.6 percent) adjusted for multifactor productivity (0.5 percentage points) results in a 2.1 percent payment update.
Rebasing the 60-Day Episode Rate - CY 2015 will be the second year of the four year phase-in for rebasing adjustments to the HH PPS payment rates.
Home Health Quality Reporting Program (HH QRP) update- The Home Health Conditions of Participations (CoPs) require HHAs to submit OASIS assessments as a condition of payment and also for quality measurement purposes. HHAs that do not submit quality measure data to CMS will see a two percent reduction in their Annual Payment Update (APU). In the final rule, CMS establishes a minimum submission threshold. Starting in CY 2015, the initial compliance threshold will be 70 percent. This means that HHAs will be required to submit both admission and discharge OASIS assessments for a minimum of 70 percent of all patients with episodes of care occurring during the reporting period.
CoPs for Speech-Language Pathologists (SLP) – CMS has also changed the conditions of participation in relation to SLP requirements. An SLP must either: a) have a masters’ or doctoral degree in speech-language pathology, and be licensed as a speech-language pathologist by the state where (s)he furnish services; or b) have successfully completed 350 clock hours of supervised clinical practicum (or be in the process of completing these hours), have at least nine months of supervised full-time speech-language pathology experience, and have successfully completed a national examination approved by the Secretary.
Home Health Value-Based Purchasing (VBP) model - CMS received numerous comments on the potential HHA VBP model. If they decide to go forward with the implementation of the VBP for home care in CY 2016, they would ask for additional comments on a more detailed model proposal.
LeadingAge NY will continue to analyze the final rule and provide a more detailed analysis.
Contact: Cheryl Udell, cudell@leadingageny.org, 518-867-8871