BriggsNetNews

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

On June 28, 2021, CMS issued a proposed rule that accelerates the shift from paying for home health services based on volume, to a system that incentivizes value and quality. The rule also seeks feedback on ways to attain health equity for all patients through policy solutions, including enhancing reports on Medicare/Medicaid dual eligible, disability status, people who are LGBTQ+; religious minorities; people who live in rural areas; and people otherwise adversely affected by persistent poverty or inequality.  This proposed rule is scheduled for publication in the Federal Register on July 7, 2021.  The public inspection copy available until July 7^th is 387 pages in length.  To be assured consideration, comments must be received at one of the addresses provided below, no later than 5 p.m. on August 27, 2021.

The CY 2022 Home Health Prospective Payment System (HH PPS) proposed rule addresses challenges facing Americans with Medicare who receive health care at home. The proposed rule also outlines nationwide expansion of the Home Health Value-Based Purchasing (HHVBP) Model to incentivize quality of care improvements without denying or limiting coverage or provision of Medicare benefits for all Medicare consumers, and updates to payment rates and policies under the HH PPS.

“Homebound Medicare patients face a unique set of challenges and barriers to getting the care they need,” said CMS Administrator Chiquita Brooks-LaSure. “Today’s announcement is a reaffirmation of our commitment to these older adults and people with disabilities who are counting on Medicare for the health care they need. This proposed rule would streamline service delivery and value quality over quantity – at a time when Americans need it most.”

The CMS Innovation Center (CMMI) developed the HHVBP Model, which began January 1, 2016, to determine whether payment incentives for providing better quality of care with greater efficiency would improve the quality and delivery of home health care services to people with Medicare. The HHVBP Model’s current participants comprise all Medicare-certified home health agencies (HHAs), providing services across nine randomly selected states. The Third Annual Evaluation Report of the participants’ performance from 2016-2018 showed an average 4.6% improvement in HHAs’ quality scores and an average annual savings of $141 million to Medicare.

CMS announced January 8, 2021 that the HHVBP model met the statutory requirements for expansion. CMS is proposing to expand the HHVBP Model nationwide effective January 1, 2022. By expanding the HHVBP Model, CMS seeks to improve the beneficiary experience by providing incentives for HHAs to provide better quality of care with greater efficiency.

Additionally, the proposed rule would improve the Home Health Quality Reporting Program by removing or replacing certain quality measures to reduce burden and increase focus on patient outcomes.  CMS would also begin collecting data on two measures promoting coordination of care in the Home Health Quality Reporting Program effective January 1, 2023 as well as measures under Long Term Care Hospital and Inpatient Rehabilitation Quality Reporting Programs effective October 1, 2022.  This would position the agency with data to monitor outcomes across diverse populations and support the recent Executive Order 13985 of January 20, 2021, entitled “Advancing Racial Equity and Support for Underserved Communities Through the Federal Government.”

More information is found at:

• Proposed Rule
• Fact Sheet

The corresponding Fact Sheet provides more specific information as to what this Proposed Rule contains, such as:

• CY 2022 Proposed Payment Updates and Policy Changes Updates for Home Health Agencies and Home Infusion Therapy Suppliers
  • Proposals and Updates to the HH PPS for CY 2022
  • Patient-Driven Groupings Model (PDGM) and Behavioral Assumptions
  • Recalibration of PDGM Case-Mix Weights
  • Occupational Therapy LUPA Add-on Factor
  • Proposals and Updates to the Home Infusion Therapy Benefit for CY 2022
  • Home Health Quality Reporting Program
• RFIs
  • Closing the Health Equity Gap – RFI
  • Fast Healthcare Interoperability Resources (FHIR) in support of Digital Quality Measurement in Quality Reporting Programs – RFI
• Long Term Care Hospital (LTCH) Quality Reporting Program and Inpatient Rehabilitation Facility (IRF) Quality Reporting Program
  • Proposing that LTCHs and IRFs begin collecting data on the Transfer of Health Information to Provider-Post Acute Care measure, the Transfer of Health Information to Patient-PAC measure and six categories of standardized patient assessment data elements effective October 1, 2022.
• Home Health Conditions of Participation
  • Make permanent selected regulatory blanket waivers related to home health aide supervision and the use of telecommunication that were issued to Medicare participating home health agencies during the COVID-19 public health emergency (PHE).
  • Update the home health Conditions of Participation to implement Division CC, section 115 of the Consolidated Appropriations Act, 2021 (CAA 2021) which requires CMS to permit an occupational therapist to conduct the initial assessment visit and complete the comprehensive assessment under the Medicare program, but only when occupational therapy is on the home health plan of care with either physical therapy or speech therapy and skilled nursing services are not initially on the plan of care.
• Survey and Enforcement Requirements for Hospice Programs
  • Provisions to implement Division CC, section 407(a) of the CAA, 2021 with respect to transparency, oversight, and enforcement of health and safety requirements for hospice programs by requiring the use of multidisciplinary survey teams, prohibiting surveyor conflicts of interest, expanding CMS-based surveyor training to accrediting organizations (AOs), and requiring AOs with CMS-approved hospice programs to begin use of the Form CMS-2567.
  • Establish a hospice program complaint hotline.
  • Create a Special Focus Program (SFP) for poor-performing hospice programs and the authority for imposing enforcement remedies for noncompliant hospice programs.