On November 6, 2014, CMS published a final rule to update the Medicare home health prospective payment system
(HH PPS) for CY 2015. CMS estimates that the final rule
will cut Medicare payments to home health agencies (HHAs) by 0.30%,
or $60 million, in 2015. Specifically, while the rule provides a
2.1% home health payment update percentage ($390 million increase),
that update is more than offset by a reduction of 2.4% ($450
million) attributable to a rebasing adjustment (the second year of
a four-year phase-in). Under the final rule, the national
standardized 60-day episode payment for CY 2015 is $2,961.38.
The final rule also adopts a number of policy proposals. Notably,
CMS is simplifying the home health face-to-face encounter
documentation requirements, including eliminating the narrative as
part of the certification of eligibility and providing more
flexibility in procedures for obtaining documentation supporting
patient eligibility. The final rule specifies that associated
physician claims for certification/re-certification of eligibility
will not be covered when a patient does not meet home health
eligibility criteria. CMS also discusses comments it received on a
potential HHA Value-Based Purchasing (VBP) model, under which CMS
would test whether payment incentives would lead to higher quality
of care for beneficiaries. CMS is considering testing such a model
beginning in 2016; additional details will be provided in future
rulemaking. The final rule also, among other things: recalibrates
HH PPS case-mix weights; simplifies therapy reassessment
timeframes; establishes a minimum OASIS assessment submission
threshold; revises the speech-language pathology personnel
conditions of participation; and places limitations on the
reviewability of civil monetary penalties imposed for HHA
noncompliance with federal participation requirements.
This article is presented for informational purposes only and is not intended to constitute legal advice.