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CMS Releases Final 2015 Payment Rule for Home Health

Friday, November 07, 2014  
Posted by: Chrissy Kissinger
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Calendar Year (CY) 2015 Home Health Prospective Payment System (HH PPS) Final Rule

On October 30, 2014 the Centers for Medicare & Medicaid Services (CMS) released its final rule for the CY 2015 Home Health Prospective Payment System.  The final rule reduces home health payments overall by 0.3 percent from 2014 payment levels, which is a total reduction of $60 million. The final rule also makes adjustment to the new home health Face-to-Face requirements; updates the Home Health Quality Reporting Program; and discusses a Value-based Purchasing Model for home health.

The payment decrease reflects the impact of the 2.1 percent home health payment update percentage ($390 million increase) and the second year of the four-year phase-in of the rebasing adjustments to the national, standardized 60-day episode payment rate, the national per-visit payment rates, and the non-routine medical supplies (NRS) conversion factor (2.4 percent or $450 million decrease).

The rule implements increases to the national per-visit payment rates, a 2.82 percent reduction to the non-routine medical supplies conversion factor, and a reduction to the national standardized 60-day episode rate of $80.95 for CY 2015. The national, standardized 60-day episode payment for CY 2015 is $2,961.38.

Face-to-Face Requirement

The regulation simplifies the requirements for the congressionally-mandated face-to-face requirements, which requires a physician to meet face-to-face with patients who are moving from acute-care hospitals and other settings to home care.  The physician is required to certify that home health services are medically necessary. Current regulations require the face-to-face encounter occur within 90 days before care begins or up to 30 days after care began. 

Prior to the CY 2015 final rule, documentation of the encounter had to include a narrative explaining why the clinical findings of the encounter support that the patient is homebound. This final rule eliminates the requirement for the inclusion of a narrative in the physician's certification of need. The certifying physician, or allowed non-physician practitioner, would still be required to certify that a face-to-face patient encounter occurred no more than 90 days prior to the start of home health, or within 30 days of the start of home care.  For medical review purposes, CMS will require documentation in the certifying physician's medical records and/or the acute/post-acute care facility's medical records (if the patient was directly admitted to home health) to be used as the basis for certification of patient eligibility. 

CMS also clarifies that a face-to-face encounter is required for certifications, rather than initial episodes; and that a certification (versus a re-certification) is generally considered to be any time a new start of care assessment is completed to initiate care. 

In addition, CMS noted that they are working on developing an electronic template that would allow electronic health records to assist providers in documenting eligibility for home health. 

CMS has created a Fact Sheet to help providers comply with the face-to-face requirement. 

Home Health Quality Reporting Program (HH QRP) Update

Current Home Health Conditions of Participations (CoPs) require Home Health Agencies (HHA) to submit OASIS assessments as a condition of payment and also in order to quality for quality measurement purposes. HHAs that do not submit quality measure data to CMS will see a two percent reduction in their annual payment update

In the 2015 final rule, CMS established a minimum submission threshold for the number of OASIS assessments that each HHA must submit. Beginning in CY 2015, the initial compliance threshold will be 70 percent. This means that HHAs will be required to submit both admission and discharge OASIS assessments for a minimum of 70 percent of all patients with episodes of care occurring during the reporting period. CMS will increase the compliance threshold to 90 percent over the next two years.

Home Health Value-based Purchasing Model

The Affordable Care Act (ACA) directed CMS to develop a plan to implement a Value-based Purchasing (VBP) program for Home Health Agencies.  VBP's are intended to tie a provider’s payment to its performance to reduce inappropriate care and reward those who provide quality care. CMS has already implemented the Hospital VBP program where 1.5 percent of hospital payments in FY 2015 are tied to the quality of care that the hospitals provide. This percentage amount will gradually increase to two percent in FY 2017 and subsequent years.

The HHA VBP model being considered would include a five to eight percent adjustment in payment made after each planned performance period in the projected five to eight states selected to participate in the model. If CMS decides to move forward with the implementation of an HHA VBP model in CY 2016, it intends to invite additional comments on a more detailed model proposal to be included in future rulemaking.

If you have any questions, please feel free to contact our Government Relations Consultant Chris Rorick at chris.rorick@bryancave.com



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