The Centers for Medicare & Medicaid Services (CMS) released the proposed CY2018 Home Health Proposed Rule (CMS-1672-P)prospective payment system (PPS) rate update that reduces overall spending and proposes the implementation of the home health groupings model (HHGM) in 2019 . The proposed rule will be published in the Federal Register on Friday, July 28, 2017.
The CY2018 Home Health Proposed Rule (CMS-1672-P) recommends:
Home health agencies will see 2018 payments reduced by 0.4%, or $80 million, based on the proposals. These include a 1%, or $190 million, home health payment update; a 0.97% decrease to the national, standardized 60-day episode payment rate to account for nominal case-mix growth for an impact of -0.9%, or a $170 million decrease; and the sunset of the rural add-on provision, a $100 million decrease.
Proposed payment methodology refinements. CMS is proposing to remove or modify 35 current OASIS items, beginning on January 1, 2019. These OASIS items, or data elements within OASIS items, are not used in the calculation of quality measures already adopted in the HH QRP, nor are they used for previously established purposes unrelated to the HH QRP, including payment, survey, the HH VBP Model or care planning. Because they will no longer be used in any manner, CMS is proposing to no longer collect them. A list of these changes can be found at https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/HHQIQualityMeasures.html.
Implementation of the home health groupings model (HHGM) in 2019. The new model could result in a $950 million Medicare payment cut for home health providers in calendar year 2019 if it is implemented in a non-budget neutral manner, and $480 million if implemented in a partially budget-neutral manner. The groupings model would replace the current 60-day episode of care unit of payment to a 30-day period effective for services beginning on or after Jan. 1, 2019. In addition to changing episode timing, the model creates six new clinical groups to categorize patients based on their primary reason for home health care. CMS is not proposing a change to the split percentage payment approach in conjunction with proposing to change the unit of payment from a 60-day episode to a 30-day period of care; however, CMS is soliciting comments on the phase-out of the split percentage payment approach in the future. The proposed case-mix methodology refinements – called the home health groupings model (HHGM) – rely more heavily on clinical characteristics and other patient information to place 30-day periods of care into meaningful payment categories. The HHGM also eliminates therapy service use thresholds that are currently used to case-mix adjust payments under the HH PPS. The proposed HHGM includes changes to the episode timing categories, the addition of an admission source category, the creation of six clinical groups used to categorize 30-day periods of care based on the patient’s primary reason for home health care, revised functional levels and corresponding OASIS items, the addition of a comorbidity adjustment, and a proposed change in the Low-Utilization Payment Adjustment (LUPA) threshold. The LUPA add-on policy, the partial payment adjustment policy, and the methodology used to calculate payments for high-cost outliers would also be revised to be consistent with the proposed 30-day period of care.
The proposed rule makes changes to the Home Health Value Based Purchasing (HHVBP) model . CMS proposes to revise the definition of “applicable measure” to specify that HHAs in the HHVBP only would have to submit a minimum of 40 completed Home Health Care Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) survey for purposes of receiving a performance score for any of the HHCAHPS measures, and to remove the Outcome and Assessment Information Set (OASIS)‑based measure, Drug Education on All Medications Provided to Patient/Caregiver during all Episodes of Care, from the set of applicable measures. CMS is also soliciting public comments on composite quality measures for future consideration.
Home Health Quality Reporting Provisions. CMS is proposing to adopt for the CY 2020 payment determination three measures to meet the requirements of the IMPACT Act. These three measures are assessment-based and are calculated using Outcome and Assessment Information Set (OASIS) data. The proposed measures are as follows:
-Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury
-Application of Percent of Residents Experiencing One or More Falls with Major Injury (NQF # 0674)
-Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631).
To meet the requirements for reporting of standardized patient assessment data required under section 1899B(b)(1) of the Act, CMS is proposing the data elements used to calculate the existing and proposed replacement pressure ulcer measures to meet the definition of standardized patient assessment data for medical conditions and co-morbidities. Additionally, CMS is proposing new, standardized data elements in four other categories: functional status; cognitive function and mental status; special services, treatments and interventions; and impairment. CMS is proposing to formalize its processes for requesting reconsideration of determinations regarding compliance with the HH QRP, as well as its policies for requesting exceptions and extensions of reporting timeframes.
Request for Information (RFI) for feedback on improving the health care delivery system, how Medicare can contribute to making the delivery system less bureaucratic and complex, and how we can reduce burden for clinicians, providers and patients in a way that increases quality of care and decreases costs –thereby making the health care system more effective, simple, and accessible while maintaining program integrity and preventing fraud. CMS is soliciting ideas for regulatory, sub-regulatory, policy, practice and procedural changes to better accomplish these goals. Ideas could include recommendations regarding payment system re-design; elimination or streamlining of reporting; monitoring and documentation requirements; operational flexibility; and feedback mechanisms and data sharing that would enhance patient care, support the doctor-patient relationship in care delivery, and facilitate patient-centered care within hospices. Ideas could also include recommendations regarding when and how CMS issues regulations and policies and how CMS can simplify rules and policies for beneficiaries, clinicians, providers, and suppliers. In responding to the RFI, CMS should be provided with clear and concise proposals that include data and specific examples. If the proposals involve novel legal questions, analysis regarding CMS’ authority is welcome. CMS will not respond to RFI comment submissions in the final rule, but rather will actively consider all input in developing future regulatory proposals or future sub-regulatory guidance.
LeadingAge is in the process of analyzing the CY2018 Home Health proposed rule and will be submitting comments on the rule. We encourage members and state affiliates to also submit comments. Comments must be received no later than 5 p.m. on September 25, 2017.
CMS-1672-P) CY2018 Home Health proposed rule https://s3.amazonaws.com/public-inspection.federal