CMS has released the 2022 Home Health Prospective Payment System (HH PPS) proposed rule. CMS is continuing to focus on value and quality in this proposed rule, instead of paying for services based on volume. The proposed rule also outlines nationwide expansion of the Home Health Value-Based Purchasing (HHVBP) Model to incentivize quality of care improvements without denying or limiting coverage or provision of Medicare benefits for all Medicare consumers, and updates to payment rates and policies under the HH PPS.
CMS first implemented the HHVBP Model in 2016. The model was designed to study if payment incentives for providing better quality would actually improve the quality of care that beneficiaries received. The HHVBP Model’s current participants comprise all Medicare-certified home health agencies providing services across nine randomly selected states. The most recent data available shows an average 4.6% improvement in agencies quality scores and an average annual savings of $141 million for Medicare. If finalized as written, the current version of the HHVBP Model would end a year early. This means that 2020 data will not be used for payment adjustments for agencies who are already participating.
The proposed rule includes annual, legally required updates to the Medicare home health payment rates for 2022. Estimated payments to agencies would increase by 1.7 percent in 2022. This reflects the proposed 1.8 percent home health payment update percentage and a 0.1 percent decrease in payments due to reductions made in the rural add-on percentages mandated by law.
Unfortunately, CMS is not making any changes to PDGM’s 4.36% behavioral adjustment. CMS will conduct an analysis on the first year of PDGM data to see what, if any changes they feel are appropriate. During the public comment period agency owners can make their voices heard about both the proposed analysis and other ways to look at the impact of the behavioral adjustment.
A new LUPA add-on for occupational therapists will begin in 2022 if the rule is finalized as it is proposed. Occupation therapists are permitted to conduct initial and comprehensive assessments when the plan of care does not initially include skilled nursing care, but includes either physical therapy or speech-language pathology. Because of this change, we are proposing conforming regulation text changes to allow for this provision. A new LUPA add-on factor would be implemented for calculating the payment amount for the first skilled occupational therapy visit in LUPA periods that occurs as the only period of care or the initial 30-day period of care in a sequence of adjacent 30-day periods of care. Currently, there is little data that applies to this change. Instead, CMS would use the physical therapy LUPA add-on factor until 2022 data is available to establish a more accurate occupational therapy add-on factor.
Agencies who have benefitted from the temporary flexibility to conduct home health aide supervisory visits via telehealth are in luck. The proposed rule would make the pandemic waiver permanent. However, CMS was careful to note that they still expect agencies to conduct the supervisory assessment during an on-site, in-person visit in most circumstances. Agencies should only use telehealth for unplanned events that interfere with scheduled visits. If finalized, it sounds like CMS will be keeping an eye out for agencies who abuse this rule.
Coordination and continuity of care has been a big focus for CMS in previous years, and with the pandemic getting under control, they have turned their attention to these issues again. CMS is proposing that home health agencies begin collecting data on the Transfer of Health Information to Provider-Post Acute Care measure, the Transfer of Health Information to Patient-PAC measure, as well as many categories of standardized patient assessment data elements that become effective January 1, 2023.
Among the smaller changes, CMS claims the proposed rule would improve the Home Health Quality Reporting Program (HHQRP) by removing or changing some measures to reduce burden. The proposed rule would eliminate the “Drug Education of All Medications Provided to Patient/Caregiver During All Episodes of Care” performance measure. According to CMS, all agencies have performed so well on this measure that they can not make meaningful distinctions between different agencies. As such, the measure does not have any value.
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