In addition to finalizing a payment rate increase of one percent under the home health prospective payment system (HH PPS) for calendar year (CY) 2018, CMS has finalized regulatory changes to reduce reporting burdens on providers. CMS removed 33 items from the Outcome and Assessment Information Set (OASIS) instrument. The agency decided not to finalize the implementation of the Home Health Groupings Model (HHGM) at this time (Final rule, 82 FR 51676, November 7 2017).
Payment rates. CMS finalized the payment rate increase as proposed and as required under the Medicare Access and CHIP Reauthorization Act (MACRA) (P.L. 114-10) (see Major changes to home health PPS proposed for 2019, July 26, 2017). Home health agencies (HHAs) that fail to submit required quality data for the HH quality reporting program (QRP) will experience a home health payment update of -2 percent on top of the one percent increase. A 0.97 percent reduction to the standardized 60-day episode rate will be applied to account for nominal case-mix growth from 2012 to 2014, in the final year of the three-year phase-in of the reduction. As of January 1, 2018, the rural add-on provision (a 3 percent increase) will no longer apply. CMS will continue to monitor the impacts of the last four years of rebasing adjustments under section 3131 of the Patient Protection and Affordable Care Act (ACA) (P.L. 111-148).
Quality reporting program. CMS has chosen to remove 33 items from the OASIS assessment after determining that they are no longer needed for the purposes of calculating quality measures, prospective payments, provider surveys, care planning, or the HH value based purchasing (VBP) model. This removal results in the collection of 235 fewer data elements within a home health episode. The agency estimated that the net burden reduction associated with the overall changes to the HH QRP is over $145 million, corresponding to a reduction in clinician burden of over 2 million hours per year.
Beginning in CY 2020, CMS is adopting three new measures for the QRP:
- changes in skin integrity post-acute care: pressure ulcer/injury;
- application of percent of residents experiencing one or more falls with major injury; and
- application of percentage of long-term care hospital patients with an admission and discharge functional assessment and a care plan that addresses function.
Groupings model. CMS proposed case-mix methodology changes through the HHGM, beginning January 1, 2019, which would use 30-day periods as opposed to the current 60-day episodes of care. The model would eliminate using the number of therapy visits to determine payment and would rely more heavily on clinical characteristics to place patients into meaningful payment categories. Although commenters were generally in support of revising the methodology to allow payments to better reflect the costs of providing care, they were concerned about changing the unit of payment and doing so in a non-budget neutral manner. Commenters also sought more information and requested involvement in the development of the model.
In response, CMS noted that significant information is available to stakeholders, and that the analysis and development of the HHGM was available to internal and external stakeholders. CMS also noted that it had made various estimates required to achieve budget neutrality under different assumptions. The agency has chosen not to finalize the HHGM at this time, and will take the comments into consideration.
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