Home Health

Breaking: 2022 proposed rule could mean national HHVBP and changes to PDGM

CMS has announced a national expansion of the Home Health Value-Based Purchasing (HHVBP) model beginning Jan. 1, 2022. It’s one of several changes introduced in the CY 2022 Home Health Prospective Payment System proposed rule, released Monday, June 28, 2021.

Previously, the nine-state HHVBP model focused on payment adjustments higher and lower compared to other agencies in the same state. CMS estimated $604.8 million in reduced spending, according to the latest annual report released May 24. The savings were driven by reductions in inpatient hospitalization and skilled nursing facility services. CMS noted no effect on Medicare spending for home health care.

In CY2020, the most recent year that data are available, payment adjustments ranged from an increase of 6% to a decrease of 5.61%, according to CMS data. Half of all agencies saw a payment adjustment between a 1.06% increase and a 1.2% decrease.

Under the proposed rule, the first year for payment adjustments would be CY 2024, with a maximum adjustment upward or downward of 5%. Instead of comparing performance on a state level, CMS will compare performance to peers nationwide, with larger- and smaller-volume cohorts based on beneficiary count in the previous calendar year.

Note: The federal Medicare agency would end the original HHVBP Model one year early for the agencies in the nine original model states, meaning payments in those states will not be adjusted in 2022.

Read the proposed rule.

Other features of the proposed rule include:

Payment rates for home health services

This rule proposes routine, statutorily required updates to the home health payment rates for CY 2022, according to CMS. Medicare payments to HHAs in CY 2022 would increase in the aggregate by 1.7%, or $310 million, based on the proposed policies. This increase reflects the effects of the proposed 1.8 percent home health payment update percentage ($330 million increase) and a 0.1 percent decrease in payments due to reductions made in the rural add-on percentages mandated by the Bipartisan Budget Act of 2018 for CY 2022 ($20 million decrease).

Monitor PDGM

CMS will continue to monitor and analyze the Patient-Driven Groupings Model (PDGM) and is seeking comments for how to measure the difference between assumed versus actual behavior change “on estimated aggregate expenditures for home health payments,” CMS states.

“CMS also proposes to recalibrate the PDGM case-mix weights, functional levels and comorbidity adjustment subgroups while maintaining the low utilization payment adjustment (LUPA) thresholds for CY 2022.”

No-pay RAP with Notice of Admission

The other big change in 2022 is that CMS is replacing the no-pay RAP with a Notice of Admission (NOA) at the start of care. CMS has been promoting this change for months, with expectations that agencies and technology vendors will have to adjust some processes to conform with the slimmed-down NOA requirements.

OT LUPA add-on factor

CMS proposed to use the “physical therapy LUPA add-on factor to establish the occupational therapy add-on factor for the LUPA add-on payment.” This change is due to another permanent change in the proposed rule: CMS will permit an occupational therapist to conduct the initial assessment visit and complete the comprehensive assessment under the Medicare program 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.

Quality reporting

CMS plans to remove one measure from the Home Health Quality Reporting Program (QRP), remove two claims-based measures and replace them with one claims-based measure, publicly report two measures.

Some waivers are permanent

Certain regulatory blanket waivers issued during the public health emergency (PHE) will be made permanent and CMS would update the home health conditions of participation regarding occupational therapists completing the initial and comprehensive assessments reflect these changes.

Hospice survey requirements

In this rule, CMS also proposes to establish survey and enforcement requirements for hospice programs.

Read the proposed rule.

Read the CMS news release.

Webinar: DecisionHealth is hosting a webinar, “Proposed PPS Rule: HHVBP and NOA explained,” presented by Kim Chapman, director of revenue cycle outsourcing at SimiTree Healthcare Consulting, on Tuesday, Aug. 10. Sign up at https://store.decisionhealth.com/proposed-pps-rule