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CHA is currently reviewing the Centers for Medicare & Medicaid Services’ calendar year (CY) 2020 proposed rule for the home health (HH) prospective payment system (PPS).
In the proposed rule, CMS continues implementation of the Patient-Driven Groupings Model (PDGM), which was finalized in the CY 2019 HH PPS final rule and goes into effect Jan. 1, 2020. CMS proposes a change to a 30-day payment amount and includes an 8.01% cut to the base rate to offset behavioral assumptions it anticipates resulting from these changes, to ensure budget neutrality when moving to the PDGM. CHA is concerned that such a significant adjustment is being proposed even prior to implementation of the new payment model, and will seek member input on this and other proposals outlined below.
CMS includes proposals to establish a permanent home infusion therapy benefit for 2021, as required by the 21st Century Cures Act. The agency also proposes to allow therapy assistants, rather than only therapists, to perform maintenance therapy.
As part of its agenda to reduce regulatory burden, CMS proposes to phase out pre-payments for home health services, phasing out Requests for Anticipated Payments over the next year and eliminating them completely by 2021.
In addition, CMS proposes to adopt two new quality measures to the Home Health Quality Reporting Program (HH QRP) addressing the “Transfer of Health Information” domain as required by the Improving Medicare Post-Acute Care Transformation Act.
Similar to the fiscal year post-acute care rules, CMS proposes to adopt several standardized patient assessment data elements (SPADEs), including those related to social determinants of health, beginning in the CY 2022 HH QRP.
Finally, CMS proposes to remove the current Pain Interfering with Activity measure and questions about pain communication from the Home Health Consumer Assessment of Healthcare Providers and Systems Survey, and to add two measures related to transfer of health information. Additionally, CMS proposes public reporting of performance data for certain HH agencies in the Home Health Value-Based Purchasing Model as soon as December 2021.
CHA will issue a summary in the coming weeks. Comments are due Sept. 9.
