CMS Eliminates RAPs, Expands Home Infusion, Updates PDGM Payment

WASHINGTON, D.C. (July 11, 2019)—The Centers for Medicare & Medicaid Services (CMS) announced on Thursday, July 11 that it had proposed a new rule to update the rates and wages for home health care for 2020, and implementing the Patient-Driven Groupings Model (PDGM), as well as other items.

The proposed rule, published in the Federal Register, also would phase out Requests for Anticipated Payments (RAPs), eliminating them completely by 2021. CMS said the proposal would increase Medicare payments to home health agencies (HHAs) by 1.3 percent ($250 million).

But the National Association for Home Care & Hospice said the proposal would actually increase the rate reduction CMS established during the 2019 rulemaking to 8.01% from 6.42% last year.

“As such, the disruptive impact of instituting a completely new payment model is compounded by a rate reduction that is wholly based on conjecture and assumptions,” NAHC President Bill Dombi said in a statement. “It appears we need the wisdom of Congress to intervene and stop this proposal from becoming reality. NAHC supports sensible payment reform. While the payment model reforms include sensible changes, the behavioral adjustment is neither sensible or warranted. Thankfully, there is bipartisan, bicameral legislation pending that can fix this serious flaw in the new payment model.”

CMS also proposed a new home infusion benefit to increase home-based care under the Home Health Prospective Payment System (Home Health PPS). The rule includes proposals for the permanent home infusion therapy benefit to be implemented in 2021 as required by the 21st Century Cures Act. This includes drug therapies as well as professional services, patient education and training and monitoring of patient care.

“We are proud to announce the new permanent home infusion therapy benefit that will give patients the freedom to safely access critical treatments, such as chemotherapy, at home instead of traveling to the hospital or doctor’s office, improving their quality of life,” CMS Administrator Seema Verma said in a news release. “We are also proposing updates to payments for home health agencies under the new Patient-Driven Groupings Model, which focuses on patient characteristics to more accurately pay for home health services, rewarding value over volume.”

In response to public feedback that CMS received under its Patients Over Paperwork Initiative, the agency is proposing to allow therapist assistants—rather than just therapists—to perform maintenance therapy. CMS said that would “allow them to practice at the top of their state licensure, give flexibility to home health providers and improve beneficiary access to these services.”

Also under the proposal, RAP payments for existing providers would be phased out over the next year and eliminated completely for 2021. CMS, which said it was making the move to reduce fraud, stated that phasing out RAP should help mitigate cash flow concerns by phasing out RAP payments over one year.

“CMS and our law enforcement colleagues have seen a marked increase in Request for Anticipated Payments (RAPs) fraud schemes perpetuated by existing HHAs that receive significant upfront payments, never submit final claims and then close for business,” the agency’s release read.

The 346-page rule, which is open for public comment until Sept. 9, 2019, also includes components that:
• Formalize plans for PDGM for services beginning on or before Jan 1, 2020 and setting the case-mix weights;
• Update the Home Health PPS rates and wage index for 2020;
• Update reporting requirements;
• Propose payment provisions for the implementation of home infusion therapy starting in 2021, after temporary payments expire in 2020;
• And other items.

You can see a CMS fact sheet on the rule here.