The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule (CMS-1648-P) that would update the Medicare Home Health Prospective Payment System (HH PPS) rates and wage index for calendar year (CY) 2017. This proposed rule addresses the following anticipated changes:
- Rebasing the 60-day Episode Rate - The CY 2017 rebasing adjustment to the national, standardized 60-day payment rate is -$80.95. The overall impact due to the rebasing adjustments is estimated to be a -2.3 percent decrease in HH PPS payments for CY 2017 which is offset by the home health payment update percentage, which would increase overall HH PPS payments in CY 2017 by 2.3 percent.
- Updates to Reflect Case-Mix Growth - CMS will implement a 0.97 percent reduction to the national, standardized 60-day episode rate in CY 2017 to account for nominal case-mix growth from 2012 to 2014 (prior to rebasing).
- Negative Pressure Wound Therapy (NPWT) - The Consolidated Appropriations Act of 2016 requires a separate payment to be made to HHAs for disposable NPWT devices when furnished on or after January 1, 2017 to an individual who receives home health services for which payment is made under the Medicare home health benefit. The separate payment amount will be set equal to the amount of the payment that would otherwise be made under the Medicare Hospital Outpatient Prospective Payment System (OPPS).
- Change in Methodology and the Fixed-Dollar Loss (FDL) Ratio Used to Calculate Outlier Payments - CMS is proposing to change the methodology used to calculate outlier payments, moving from a cost per visit approach to a cost per unit approach (1 unit = 15 minutes).
- New IMPACT Act Cross-Setting Measures - CMS is proposing to adopt for the CY 2018 payment determination four measures to meet the requirements of the IMPACT Act. The proposed measures are:
- All-condition risk-adjusted potentially preventable hospital readmission rates (claims-based)
- Total estimated Medicare spending per beneficiary (claims-based)
- Discharge to the community (claims-based)
- Medication reconciliation (OASIS-based).
- Payment Penalties related to OASIS Submissions - HHAs that do not submit quality measure data to CMS will see a two percent reduction in their annual payment update (APU). CMS is incrementally increasing the compliance threshold over a three-year period beginning with the reporting period for CY 2017.
- Comprehensive Reevaluation of all 81 HH Quality Measures - As a result of a Technical Expert Panel comprehensive reevaluation, CMS identified 28 home health quality measures that were either “topped out” and/or determined to be of limited clinical and quality improvement value. These measures will no longer be included in the HHQI. A list of these measures, along with our reasons for no longer including them in the HHQI, can be found at the following link https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/HHQIQualityMeasures.html.
- Home Health Value-Based Purchasing Model - CMS proposes the following changes and improvements related to the HHVBP Model:
- Calculate benchmarks and achievement thresholds at the state level rather than the level of the size-cohort and revise the definition for “benchmark” to state that benchmark refers to the mean of the top decile of Medicare-certified HHA performance on the specified quality measure during the baseline period calculated for each state;
- A minimum requirement of eight HHAs in a size-cohort;
- Increase the timeframe for submitting New Measure data from seven calendar days to fifteen calendar days following the end of each reporting period to account for weekends and holidays;
- Remove four measures (Care Management: Types and Sources of Assistance, Prior Functioning ADL/IADL, Influenza Vaccine Data Collection Period, and Reason Pneumococcal Vaccine Not Received) from the set of applicable measures;
- Adjust the reporting period and submission date for the Influenza Vaccination Coverage for Home Health Personnel measure from a quarterly submission to an annual submission; and
- Add an appeals process that includes the existing recalculation process and adds a reconsideration process.
See More Posts...