CMS Issues Proposed Rule Updating the Home Health Prospective Payment System.

The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule updating the Medicare Home Health Prospective Payment System (HHPPS) for calendar year (CY) 2018. For CY 2018, CMS projects that Medicare payments to home health agencies would be reduced by 0.4 percent, or $80 million, based on the proposed policies. The rule proposes to refine the case-mix methodology, through the home health groupings model (HHGM), to change the unit of payment from 60-day episodes of care to 30-day periods of care beginning on or after January 1, 2019. The HHGM relies 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 currently in used with respect to case-mix adjust payments under the HH PPS.

Important policy changes under the proposed rule include:

• Adoption of three measures to meet the Improving Medicare Post-Acute Care Transformation Act of 2014 (the IMPACT Act) requirements for the CY 2020 payment determination. The three measures are assessment-based and are calculated using Outcome and Assessment Information Set (OASIS) data:

• • 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); and
  • 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).
• Removal or modification of 35 current OASIS items, beginning on January 1, 2019;
• Modification to the Home Health Value-Based Purchasing (HHVBP) Model requiring participating HHAs to submit only a minimum of 40 completed Home Health Care Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) surveys to receive a performance score for any of the HHCAHPS measures; and
• Removal of the OASIS?based measure entitled Drug Education on All Medications Provided to Patient/Caregiver during all Episodes of Care.

Additionally, CMS has issued the same Request for Information (RFI) set forth in the Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule and the Medicare Physician Fee Schedule Proposed Rule to solicit feedback on methods for achieving more transparency, flexibility, program simplification, and innovation in the health care delivery system.

The HH PPS proposed rule is available at:

https://www.gpo.gov/fdsys/pkg/FR-2017-07-28/pdf/2017-15825.pdf.