On June 26, 2020, the Centers for Medicare and Medicaid Services (CMS) released the Home Health proposed rule for 2021.
There were little to no changes with the PDGM payment model and it’s clear that PDGM is here to stay. Additional highlights from this proposed rule are listed below:
- There is a proposed increase overall reimbursement by 2.7% over 2020 rates with the CY2021 national standardized 30 day payment period to be at $1,874.64.
- Significant changes to home health agencies who complete infusion therapy including an enrollment process in order to provide home infusion that would begin. There is no significant changes to reimbursement related to infusions, but an application fee cost to agencies who enroll that equates to approximately $31,050 the second year, and $31,00 in the third year.
- Significant proposed changes to the RAP (Request for Anticipated Payment) process in 2021 and then the NOA (Notice of Admission) process beginning in 2022 with financial penalties associated with this process. The RAP process will remain in place for 2021 but then be eliminated in 2022 and replaced with a notification of admission (NOA) which will no longer have any reimbursement associated with it. If the RAP and NOA is not submitted within 5 calendar days from the start of care date, a reduction in payment equal to one-thirtieth of the case-mix adjusted 30 day payment period will be applied for every day past the 5 day window in which the RAP or NOA is delayed in submission.
- There was acknowledgement within the proposed rule specific to remote patient monitoring and services furnished via a telecommunications system. As finalized in the COVID relief regulatory updates, these services will need to clearly outlined in the home health plan of care and be tied to patient-specific needs as identified in the comprehensive assessment, and facilitate the achievement of goals. Although there is still no reimbursement proposed for telehealth services and they cannot be a substitute for in-person visits as it relates to reimbursement. CMS states that they do not have the authority to introduce payment for telehealth and that would need to be done via Congress.
The comment period in response to the final rule is open for the next 60 days for providers to provide feedback to CMS in regards to the proposed rule.
HealthPRO Heritage at Home is prepared to help you execute and succeed as we enter 2021 and beyond! We are focused on providing resources, education, and support to home health agencies. Our experts are here to help. Contact us with questions or reach out for additional perspective: homehealth@healthpro-heritage.com.
