Policy & Regulation News

Proposed 2015 home health PPS refinements, rate update

By Elizabeth Snell

- On Monday, July 7, 2014, the Centers for Medicare & Medicaid Services (CMS) announced a proposed rule for the home health prospective payment system (HH PPS) refinements and refine update for the calendar year (CY) 2015. The proposed rule also includes changes to simplify the face-to-face encounter regulatory requirements, changes to the HH PPS case-mix weights, changes to the home health quality reporting program requirements and changes to simplify the therapy reassessment timeframes. Additionally, the proposed rule discusses a revision to the Speech-Language Pathology (SLP) personnel qualifications, minor technical regulations text changes, as well as limitations on the reviewability of the civil monetary penalty provisions.

The overall economic impact of this proposed rule is an estimated $58 million in decreased payments to home health agencies (HHAs). The CMS proposed rule is also expected to create a net reduction in burden of $21.55 million associated with certifying patient eligibility for home health services & certification form revisions.

Here is a quick rundown of the details of the proposed rule:

Monitoring for potential impacts

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  • CMS plans to monitor for potential impacts of Affordable Care Act rebasing adjustments that were finalized in the CY 2014 HH PPS finale rule.

    This is the second year of the four-year phase-in of the rebasing adjustments to the national, standardized 60-day episode payment amount, the national per-visit rates and the NRS conversion factor. The rebasing adjustments for CY 2015 would reduce the national, standardized 60-day episode payment amount and then increase the national per-visit payment amounts by 3.5 percent of the national per-visit payment amounts in CY 2010.

    Face-to-face encounter requirements

    CMS proposes changes to the face-to-face encounter narrative requirement, as well as to the non-coverage of associated physician certification/re-certification claims. With the proposed rule, CMS wants to simplify the face-to-face encounter regulations, reduce burden for HHAs and physicians, and mitigate instances where physicians and HHAs unintentionally fail to comply with certification requirements.

    When documentation of a face-to-face encounter is required

    CMS wants to clarify when documentation of a face-to-face encounter is required. The proposed rule would clarify that a certification is considered to be any time a that a new start of care OASIS is completed to initiate care.

    Recalibration of the HH PPS case-mix weights

    CMS proposes to recalibrate the case-mix weights, adjusting the weights relative to one another using more current data and aligning payments with current utilization data in a budget neutral manner. Specifically, with the proposed rule CMS will apply the full 1.0237 case-mix budget neutrality factor to the national, standardized 60-day episode payment rate. We will continue to monitor case-mix growth and may consider whether to propose nominal case-mix reductions in future rulemaking.

    CY 2015 rate update

    CMS proposes an update for the payment rates under the HH PPS by the home health payment update percentage of 2.2 percent (using the 2010-based Home Health Agency [HHA] market basket update of 2.6 percent, minus a 0.4 percentage point reduction for productivity.

    The proposed rule also suggests changes to the home health quality reporting program, including the establishment of a minimum threshold for submission of OASIS assessments for purposes of quality reporting compliance. Additionally, CMS proposes the establishment of a policy for the adoption of changes to measures that occur in-between rulemaking cycles as a result of the NQF process, as well as and submission dates for the HHCAHPS Survey moving forward through CY 2017.

    Implementation of ICD-10 Clinical Modification (ICD-10-CM)

    CMS also discusses in the proposed rule the delay in the implementation of ICD-10-CM, which will be required as of October 1, 2015. Until that time, ICD-9-CM diagnosis codes will continue to be used for home health claims. CMS wants to disseminate the details pertaining to the coding through the HHA Center Web site, the Home Health, Hospice and DME Open Door Forum, and in the CY 2015 HH PPS final rule.

    Other provisions

    Under the proposed rule, CMS will also discuss changes to the therapy reassessment timeframes, the HHA value-based purchasing model, proposed revisions to the speech-language pathologist personnel qualifications as well as proposed text changes for technical regulations and the enforcement requirements for home health agencies.