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CMS Releases 2019 Home Health Final Rule

On Wednesday, October 31st, the Centers for Medicare and Medicaid Services (CMS) released the Calendar Year 2019 Home Health Prospective Payment System Final Rule, which outlines payment updates, changes to certification/recertification requirements to reduce physician burden, changes regarding remote patient monitoring and home infusion under the home health (HH) benefit, modifications in the Home Health Value-Based Purchasing and Quality Reporting Programs, and a new payment system, the Patient-Driven Groupings Model, to be implemented January 1, 2020.

Payment Updates

CMS finalized that Medicare payments for 2019 would increase 2.2%, or $420 million. The Low Utilization Payment Adjustment (LUPA) will remain the same in 2019, and the rural add-on adjustment amount will depend on whether the beneficiary lives in a high-utilization area, a low population-density area, or “other” rural area. In addition, the rural add-on will change over the next 4 years as follows:

Rural counties or equivalent areas classified as high utilization, low population density, or “other” in 2019 will remain designated as such through 2022.

Reducing Physician Burden

CMS will eliminate the requirement that the physician estimate how much longer skilled services would be needed when they recertify home health services because this information is already documented on the patient’s plan of care. CMS will also modify current regulations to align with sub-regulatory guidance allowing the use of home health agency (HHA) medical record documentation to help support the basis for home health care (that is, the need for skilled service and the patient’s homebound status), consistent with the Bipartisan Budget Act of 2018. CMS goes on to say that HHA-generated documentation for the patient is not sufficient on its own, but it can be used along with documentation from the certifying physician and/or from the facility (in the case of an institutional admission) to support eligibility for HH services.

Remote Patient Monitoring

In the Final Rule, CMS defines remote patient monitoring under the HH benefit 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 HHA.” And, CMS states HHAs can use remote patient monitoring to augment the care planning process. If remote patient monitoring is used in this manner, the associated costs may be included on the Agency’s cost report as allowable administrative costs factored into cost per visit.

Home Infusion Services

The Bipartisan Budget Act of 2018 and the 21st Century Cures Act of 2016 required CMS to implement a new home infusion benefit under Medicare Part B. In the Final Rule, CMS established requirements for suppliers of home infusion therapy, standards for the delivery and payment of home infusion services, and details around the accreditation organizations for the suppliers of home infusion services. In addition, CMS finalized a temporary transitional payment for home infusion therapy in 2019 and 2020, in anticipation of full implementation in 2021. For 2019 and 2020, certain DME and pharmacy suppliers will be eligible to receive payment under Part B for home infusion; HH and hospice providers become eligible in 2021.

Home Health Value-Based Purchasing (VBP) Program

For 2019, CMS finalized the removal of 2 measures (for the flu and pneumonia vaccines) and replaces 3 other function-based measures with 2 new composite measures to measure the change in self-care and change in mobility. CMS has also reweighted the measure categories for HH VBP for purposes of calculating the HHA’s Total Performance Score, and has modified the maximum number of improvement points to help support the VBP program’s overall goal of encouraging home health agencies to provide high quality care and to focus on achievement, rather than simply improving in measure performance.

Home Health Quality Reporting Program (QRP)

In consideration of CMS’s Meaningful Measures Initiative, CMS will remove 7 quality measures from the HH QRP beginning in 2021 based on 8 quality removal factors. CMS will increase the number of years of QRP data collection for public display from 1 to 2 years, increasing the number of home health agencies with enough data for public reporting. CMS also plans to begin publicly reporting information on the Medicare Spending Per Beneficiary measure in January, 2019.

Patient Driven Groupings Model

The Bipartisan Budget Act of 2018 mandates changes to the current HH Prospective Payment System, including changing from a 60-day episode of care to a 30-day payment period and the elimination of therapy thresholds (or a number of therapy visits) as payment factor. In response to this legislation, CMS proposed an updated version of the Home Health Groupings Model proposed for CY 2018, called the Patient-Driven Groupings Model, or PDGM. In the Final Rule, CMS confirmed that PDGM, with some minor modifications, will be implemented in a budget-neutral manner on January 1, 2020. In PDGM, payment is based on patient characteristics, rather on the services provided to the patient. Click here for more information on PDGM.

For additional information on the 2019 HH Final Rule, click here.

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