6 Takeaways from CMS’s Latest Proposed Rule

The overall economic impact of the updated home health PPS payment rate update is an estimated $400 million (2.1 percent) in increased payments to home health agencies in CY 2019, and the rule makes way for home infusion therapy suppliers to see an estimated $60 million in increased payments.

CMS Administrator Seema Verma offered the update as solutions: for giving doctors more time to spend with their patients and for allowing home health agencies to leverage innovation and drive better results for patients; for businesses, allowing the cost of remote patient monitoring to be reported by home health agencies as allowable costs on the Medicare cost report form. Meant to modernize Medicare by design, the update targets the agency’s preference for value over volume, and “removes incentives to provide unnecessary care.”

The proposed rule (CMS-1689-P) also includes information on the implementation of home infusion therapy temporary transitional payments as required by the Bipartisan Budget Act of 2018. In addition, the proposed rule solicits comments on elements of the new home infusion therapy benefit category and proposes standards for home infusion therapy suppliers and accrediting organizations of these suppliers as required by the 21st Century Cures Act.

Physicians who order home health services for their patients would also see administrative burden reduced under CMS-1689-P. CMS is proposing to eliminate the requirement that the certifying physician estimate how much longer skilled services would be needed when recertifying the need for continuing home health care, as this information is already gathered on a patient’s plan of care.

According to CMS, the July 2, 2018, proposed rule helps advance the Trump administration’s Meaningful Measures Initiative. CMS is proposing changes to the Home Health Quality Reporting Program (HH QRP). The cost impact related to updated data collection processes as a result of the proposed implementation of the PDGM and proposed changes to the HH QRP are estimated to result in a net $60 million in annualized cost savings to home health agencies (HHAs), or $5,150 in annualized cost savings per HHA, beginning in calendar year 2020.

Additionally, the CMS says the update will accelerate data sharing among patients, their caregivers and their providers. Supporting patients in sharing this data will advance the Administration’s MyHealthEData initiative.

6 Takeaways from CMS’s Latest Proposed Rule

1. Renames the former home health groupings model (HHGM) to the patient-driven groupings model (PDGM).

2. Proposes to define “remote patient monitoring” and recognize the cost associated as an allowable administrative cost. Through the rule, CMS defined remote patient monitoring as “the collection of physiologic data (for example, ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the home health agency.

3. Proposes case-mix methodology refinements to be implemented for home health services beginning on or after January 1, 2020, including a change in the unit of payment from 60-day episodes of care to 30-day periods of care, as required by section 51001 of the Bipartisan Budget Act of 2018.

4. Solicits comments regarding payment for home infusion therapy and proposes health and safety standards, as well as an accreditation and oversight process for home infusion therapy suppliers.

5. Proposes changes to the home health value-based purchasing (HHVBP) model to remove two OASIS-based measures, replace three OASIS based measures with two new proposed composite measures, rescore the maximum number of improvement points, and reweight the measures in the applicable measures set. Improvement in ambulation-locomotion, improvement in bed transferring and improvement in bathing will be replaced with two proposed composite measures on total normalized composite change in self-care and mobility.

6. Clarifies that not all OASIS data is required for the HH QRP.

As part of the proposed rule, CMS released a Request for Information to welcome continued feedback on the Medicare program and interoperability. CMS is gathering stakeholder feedback on revising the CMS patient health and safety standards that are required for providers and suppliers participating in Medicare and Medicaid programs to further advance electronic exchange of information that supports safe, effective transitions of care between hospitals and community providers. Comments are due to CMS by no later than 5 p.m., August 31, 2018, by mail or electronically via regulations.gov (follow the instructions in the rule).

More information and a quick fact sheet on the proposed rule here.

— HomeCare Staff Report