The Centers for Medicare & Medicaid Services (CMS) has issued the proposed calendar year (CY) 2020 update to Medicare home health prospective payment system (HH PPS) rates and policies. The proposed rule also would update transitional home infusion therapy rates for CY 2020 and institute permanent infusion therapy payment reforms beginning in CY 2021.
With regard to home health policy, CMS projects that aggregate CY 2020 HH PPS payments would increase by 1.3%, or $250 million, compared to 2019 levels under the proposed rule. As established in the CY 2019 final rule, CMS will implement its new case mix methodology, the “Patient-Driven Groupings Model” (PDGM), effective January 1, 2020. The proposed CY 2020 HH PPS update reflects the transition to the PDGM methodology and a new 30-day payment unit, with CMS proposing downward adjustments for certain anticipated “behavior changes” such as modifications to documentation and coding practices. The proposed update also makes other adjustments, including to incorporate a new rural add-on policy, updated wage index data, and an updated fixed-dollar loss ratio for outlier payments. The proposed 2020 national, standardized 30-day payment for an HHA that submits required quality data is $1,791.73 (compared to the CY 2019 national, standardized 60-day episode payment of $3,154.27). The proposed rate for an HHA that does not submit required quality data is $1,756.42.
In addition to the HH PPS rate update, CMS proposes to make a number of HHA policy changes, including: streamlining home health plan of care content requirements; allowing physical therapy assistants to furnish maintenance therapy; modifying the split percentage payment policy (with elimination of split-percentage payments beginning in CY 2021); and updating Home Health Quality Reporting Program and Home Health Value-Based Purchasing Model requirements.
The proposed rule also continues to implement refinements to Medicare payment policy for home infusion therapy services, as mandated by the 21st Century Cures Act. In the final 2019 rule, CMS established a new temporary transitional payment for home infusion therapy services in 2019 and 2020, in advance of implementation of a new home infusion therapy benefit in 2021. The proposed 2020 rule would update the temporary transitional payment rates for 2020 based on corresponding CY 2020 Physician Fee Schedule (PFS) amounts (which are expected to be released in the near future). For 2021, CMS proposes fully implementing the new home infusion therapy benefit, with home infusion drugs classified into three payment categories, each of which would have a single unit of payment based on PFS amounts (such amounts would be adjusted by the geographic adjustment factor). CMS proposes establishing higher payment amounts for the first home infusion therapy visit; for subsequent visits, CMS would apply a small decrease to the payment amounts to maintain budget neutrality.
CMS will accept comments on the proposed rule until September 9, 2019.