The Centers for Medicare & Medicaid Services (CMS) has proposed its annual update to Medicare home health prospective payment system (HHS PPS) rates for calendar year 2019, along with a broader case-mix methodology reform proposal that would be implemented beginning in 2020.
With regard to the 2019 update, CMS proposes a 2.1% rate increase ($400 million) based on a home health agency (HHA) market basket update of 2.8%, minus a 0.7 percentage point multifactor productivity adjustment. Payments would also reflect a 0.1% increase tied to outlier payment spending and a 0.1% decrease stemming from a new statutory rural add-on classification policy. The proposed 2019 national, standardized 60-day episode payment rate is $3,151.22, compared to the 2018 rate of $3,039.64; the rate for an HHA that does not submit required quality data would be $3,089.49.
The proposed rule includes numerous proposals that would impact home health benefit and payment policies. For instance, the proposed rule would define remote patient monitoring in the Medicare home health benefit and add the cost of remote patient monitoring as an allowable HHA administrative cost. It also would provide a temporary transitional payment for home infusion therapy services in 2019 in advance of full implementation of a new home infusion therapy benefit in 2020. CMS proposes new safety and accreditation standards for home infusion therapy suppliers, and seeks comments regarding payment for home infusion therapy services beginning in 2021. CMS also proposes changes to Home Health Quality Reporting Program policies, including removal of seven quality measures under a new measure removal factor, in addition to proposed refinements to Home Health Value-Based Purchasing Model measures and performance scoring. A number of provisions of the rule are designed to reduce regulatory burdens, including changes to the physician certification/recertification process to eliminate the requirement that certifying physicians estimate how much longer skilled services will be needed when recertifying patient eligibility for home health care.
CMS proposes broader reforms for 2020, as mandated by the Bipartisan Budget Act of 2018. The newly-developed Patient-Driven Groupings Model (PDGM) is intended to base HHA reimbursement on patient clinical characteristics, rather than therapy service thresholds. The model would move to 30-day episodes of care, rather than the current 60-day episode, and would be implemented in a budget-neutral manner.
The proposed rule includes a Request for Information (RFI) seeking feedback on the possibility of revising the Conditions of Participation related to interoperability as a way to increase electronic sharing of data by providers. A second RFI requests input on ways to improve the accessibility and usability of home health charge information to help patients understand what their potential financial liability might be and to enable patients to compare charges for similar services across providers and suppliers. CMS will accept comments on the proposed rule and RFIs through August 31, 2018.