The Centers for Medicare and Medicaid Services (CMS) released the Home Health 2022 proposed rule on Monday, June 28, 2021. We're breaking down the details, enjoying the fireworks (including a slight increase in reimbursement!), and talking future of home health.
Most Notable Elements of the Proposed Rule
CMS is proposing a $310M increase in Home Health payments in 2022, which equates to an increase in payment by 1.8%! This proposed increase adjusts the 30-day payment base rate from $1901.12 to $2012.43. However, despite quite a bit of controversy and advocacy efforts to have the behavioral adjustments that were implemented in 2020 with the conversion to PDGM modified, they remain intact at a 4.36%.
Let's Talk Future of Home Health: Nationwide Value-Based Purchasing
The most notable aspect of the proposed rule is the expansion of the HHVBP (Home Health Value-Based Purchasing) demonstration to the entire nation including Washington DC as of January 1, 2022. CY 2022 will be the first performance year for all agencies with CY 2024 being the first payment year with a proposed maximum payment adjustment (upward or downward) of 5%. This expanded model would use applicable quality measures for home health agencies to compete nationally in their applicable cohort (smaller or larger volume agencies). CMS is also proposing the end of the original HHVBP Model one year early and therefore CY2020 data will not be used to apply any payments adjustments in those nine states currently participating.
The HHVBP Model was designed to incentivize Medicare-certified home health agencies to efficiently provide higher quality care. The HHVBP Model supports the Department of Health and Human Services’ efforts to build a health care system that delivers better care, spends health care dollars more wisely, and results in healthier people and communities. HealthPRO Heritage has been preparing agencies for this over the past years, thus we have the tools and resources your agency needs to be successful under HHVBP.
The current HHVBP Model utilizes data from OASIS, Medicare claims, Home Health CAHPS surveys, and other directly reported data to evaluate HHAs on a specific set of 24 measures:
Outcome Measures (CASPER reports):
- Improvement in Ambulation (M1860)
- Improvement in Bed Transferring (M1850)
- Improvement in Bathing (M1830)
- Improvement in Dyspnea (M1400)
- Discharged to Community (M2420
- Acute Care Hospitalization (Claims)
- ER Utilization without Hospitalization (Claims)
- Improvement in Pain with Activity (M1242)
- Improved Management of Oral Medications (M2020)
- Prior Functioning ADL/IADL (M1900)
Process Measures (CASPER reports):
- Care Management-Types/Sources of Assistance (M2102)
- Influenza Data Collection Period (M1041)
- Influenza Immunization Received for Current Flu Season (M1046)
- Pneumococcal Vaccine Ever Received (M1051)
- Reason Pneumococcal Not Received (M1056)
- Drug Education on All Medications Provided to the Patient/Caregiver (M2015)
Home Health CAHPS Satisfaction Survey Measures:
- Care of Patients
- Communication between Providers and Patients
- Specific Care Issues
- Overall Rating of Home Health Care
- Willingness to Recommend the Agency
Agency-Reported Measures:
- Influenza Vaccination Coverage for Home Health Personnel
- Herpes Zoster (Shingles) Vaccination Ever Received by Patient
- Advance Care Planning
Additional Highlights from the Proposed Rule are as Follows:
- The expansion of “allowed practitioners” to establish and periodically review the Home Health plan of care. This includes nurse practitioners, physician assistants, and clinical nurse specialists as allowed by state practice and licensure acts.
- A proposed change to allow occupational therapists to complete initial and comprehensive assessments when ordered with another therapy service (either physical therapy or speech therapy). This will apply to cases where skilled nursing services are not also ordered.
- Proposed changes to home health care aide supervisory visits to follow some of the Public Health Emergency flexibility including allowance of virtual supervision. Although CMS has indicated virtual supervision only be completed when in-person visits are not able to be coordinated and at a limit of 2 times per 60 day period.
- The QRP (Quality Reporting Program) is proposed to be updated to remove one of the OASIS-based process measures: Drug Education on All Medications Provided to Patient/Caregiver. The removal of this measure is based on the performance being high enough that meaningful distinctions between agency performances can no longer be made.
- There is also a proposal to replace two outcomes measures: (1) Acute Care Hospitalization during the First 60 days of Home Health and (2) Emergency Department Use without Hospitalization during the First 60 Days of Home Health with a Potentially Preventable Hospitalization (PPH) measure beginning in 2023.
- CMS is also proposing the additional reporting of Percent of Residents Experiencing One or More Major Falls with Injury and Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function measure beginning in April 2022.
- There are a number of proposed changes to Home Infusion Therapy (HIT) including provisions to the provider and supplier enrollment process and an update to payment rates for CY 2022.
Interestingly enough, early PDGM data for 2020 has indicated that there was a 21.6% decrease in Home Health spending compared to original CMS projections as well as the budget neutrality that was mandated in the Bipartisan Budget Act of 2018.
The comment period in response to the proposed rule is open for the next 60 days for providers to provide feedback to CMS.
What Does This Mean for Your Agency?
OASIS education and accuracy is the key to attaining improved quality scores and revenue. Additionally, home health agencies will need to utilize Quality Assessment Performance Improvement (QAPI) programs to the forefront. We have the tools and resources to make your agency successful through these upcoming regulatory changes by providing proven and evidence-based strategies based on our current record of accomplishment.
HealthPRO Heritage offers:
- On-site Project Home Health Agency Management
- Proprietary PDGM Calculator Tool
- 20 Therapy Clinical PDGM Pathways (specific tests, assessments, benchmarks, etc.)
- 12 Nursing Clinical PDGM Pathways (specific visit goals, assessments, and education tools)
- COQS OASIS Coding and Scrubbing (average of $486 in revenue found per chart)
- Specialized Program Development (Cardiac, Orthopedic, Falls, etc.)
- QAPI Development and Oversight
- State/JACHO Mock Survey Preparedness
- Educational Resources
- Census Development
HealthPRO Heritage is prepared to help you execute and succeed as we enter 2022 and beyond! We are focused on providing resources, education, and support to home health partners. Our experts are here to help. Contact us with questions or reach out for an additional perspective by emailing: homehealth@healthpro-heritage.com.