Late Thursday afternoon, CMS released the Final Rule for 2015 Medicare HHPPS payment rates that are expected to reduce payments to Home Health Agencies by 0.30 percent or $60 Million! In addition, CMS finalized other proposals which included simplifying the face-to-face encounter policy and therapy reassessment requirements.
Changes within the home health industry related to payment updates can greatly impact agencies that are not prepared for the adjustments. At Mueller Prost, we understand that agency owners, administrators, and executives do not have time to read the 259 page final rule and we are here to help! Let the experts ensure compliance within your agency!
CY 2015 Annual Payment Update:
For CY 2015, home health payment rates for services provided to beneficiaries in areas that are defined as rural under the new OMB delineations will be increased by 3 percent as mandated by section 3131(c) of the Affordable Care Act. The 3 percent rural add-on is applied to the national, standardized 60-day episode payment rate, national per visit rates, and NRS conversion factor when HH services are provided in rural (non-CBSA) areas.
- CY 2015 National Standardized 60-Day Episode Payment Rate for HHAs that submit Quality Data: $2,961.38
- CY 2015 National Standardized 60-Day Episode Payment Rate for HHAs that DO NOT submit Quality Data: $2,903.37
- CY 2015 National Standardized 60-Day Episode Payment Rate for HHAs that submit Quality Data: $3,050.22
- CY 2015 National Standardized 60-Day Episode Payment Rate for HHAs that DO NOT submit Quality Data: $2,990.47
Click here to use our calculator to determine specific amounts based on your agency's specifics.
CY 2015 Home Health Rate Update:
"After consideration of the public comments received, we are adopting as final, our proposal to establish a pay-for- reporting performance requirement, with the modifications stated below:
- For episodes beginning on or after July 1st, 2015 and before June 30th, 2016, HHAs must score at least 70 percent on the QAO metric of pay-for-reporting performance requirement or be subject to a 2 percentage point reduction to their market basket update for CY 2017.
- We defer for now from setting a minimum OASIS reporting requirement for the 2nd and subsequent years of the OASIS “pay-for-reporting” performance requirement program. However, we will consider increasing the requirement in subsequent years. We anticipate rates of at least 80 percent or higher, not exceed 90 percent, in years 2 and 3."
Is your agency meeting the requirements of the QAO metric of pay-for-reporting? If you are not sure, please contact us for help!
Recalibration of the HHPPS Case-Mix Weights:
Final Decision: "We are finalizing the points for the case-mix variables, the revised thresholds for the clinical and functional levels, and the case-mix weights for CY 2015 shown in the tables above. We are also finalizing our proposal to recalibrate the case-mix weights every year with more current data. We will continue to monitor case-mix growth and may consider whether to propose nominal case-mix reductions in future rulemaking."
Our calculator includes the new case-mix variables! Be sure to check it out.
Changes to the Face-To-Face Requirement:
Final Decision: We are finalizing our proposal to eliminate the face-to-face encounter
narrative as part of the certification of patient eligibility for the Medicare home health benefit,
effective for episodes beginning on or after January 1, 2015. The certifying physician will still
be required to certify that a face-to-face patient encounter, which is related to the primary reason the patient requires home health services, occurred no more than 90 days prior to the home health start of care date or within 30 days of the start of the home health care and was performed by a physician or allowed non-physician practitioner as defined in §424.22(a)(1)(v)(A), and to document the date of the encounter as part of the certification of eligibility. For instances where the physician is ordering skilled nursing visits for management and evaluation of the patient's care plan, the physician will still be required to include a brief narrative that describes the clinical justification of this need as part of the certification/re-certification of eligibility as outlined in §424.22(a)(1)(i) and §424.22(b)(2).
In determining whether the patient is or was eligible to receive services under the
Medicare home health benefit at the start of care, we 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 home health eligibility. We will require the documentation to be provided upon request to the home health agency, review entities, and/or CMS. Criteria for patient eligibility are described at CMS-1611-F 61 §424.22(a)(1) and §424.22(b). HHAs should obtain as much documentation from 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) as they deem necessary to assure themselves that the Medicare home health patient eligibility criteria have been met and must be able to provide it to CMS and its review entities upon request. If the documentation used as the basis for the certification of eligibility is not sufficient to demonstrate that the patient is or was eligible to receive services under the Medicare home health benefit, payment will not be rendered for home health services provided.
Although this is an improvement to the current standard, your agency should be well informed of the regulation relating to face-to-face documentation. For assistance with training your staff, please contact us.
Change to the Therapy Reassessment Time Frames
Final Decision: In summary, we are finalizing changes to the regulations at §409.44,
effective for episodes ending on or after January 1, 2015, to require that at least every 30 days a qualified therapist (instead of an assistant) must provide the needed therapy service and
functionally reassess the patient. Where more than one discipline of therapy is being provided, a qualified therapist from each of the disciplines must provide the needed therapy service and
functionally reassess the patient at least every 30 days. Therapy reassessments are to be
performed using a method that would include objective measurement, in accordance with
accepted professional standards of clinical practice, which enables comparison of successive
measurements to determine the effectiveness of therapy goals. Such objective measurements
would be made by the qualified therapist using measurements which assess activities of daily
living that may include but are not limited to eating, swallowing, bathing, dressing, toileting,
walking, climbing stairs, or using assistive devices, and mental and cognitive factors. The
measurement results and corresponding effectiveness of the therapy, or lack thereof, must be
documented in the clinical record.
Again, this is an improvement to the current standard, but your agency still must be complying with reassessments every 30 days. If your staff needs assistance tracking this or understanding the regulation, please contact us for help.