Home Health

Final Rule: CMS delays HHVBP implementation

CMS is giving agencies time to prepare before the national rollout of the Home Health Value-Based Purchasing model (HHVBP) begins impacting payments.

That’s one of the big changes in CMS’ Home Health Prospective Payment System final rule, released late Tuesday, Nov. 2, 2021.

The HHVBP model will adjust payments based on how an agency performs on a handful of quality measures.

Originally expected to begin implementing HHVBP in January, CMS is now going to use 2022 as a “pre-implementation year.” This change means the first year for payment adjustments will be 2025, with 2023 as the first performance year.

“Throughout 2022, CMS will provide technical assistance to HHAs to ensure they understand how performance will be assessed,” according to a CMS statement Tuesday.

In 2020, half of all agencies in the nine model states saw a payment adjustment between a 1.06% increase and a 1.2% decrease.

The federal Medicare agency is also ending 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.

Other news in the final rule:

Payment rates for home health services. The total estimated increase in payments based on the rule would be $570 million, or 3.2%.

That includes:

  • an estimated home health payment update of 2.6%, or $465 million
  • an additional 0.7 percent increase ($125 million) that reflects the effects of an updated fixed-dollar loss (FDL), which was not accounted for in the proposed rule in June
  • and a 0.1 percent decrease ($20 million) in payments due to the changes in the rural add-on percentages for 2022

OASIS-E in 2023. After a two-year delay in implementation due to the PHE, OASIS-E will be required for assessments beginning Jan. 1, 2023. This replaces a schedule that would have delayed the OASIS-E until the January one full year after the public health emergency (PHE).

CMS officials have previously noted they will provide the training and education for HHAs to be prepared for this implementation, with a draft of the updated version of the OASIS-E expected to be released in early 2022.

Other quality reporting changes.

  •  Removes “Drug education on all medications provided to patient caregiver” beginning in 2023. Data for this measure will be publicly reported through Oct. 1, 2023.
  • Replaces “Acute care hospitalization” and “Emergency department use without hospitalization” during the first 60 days with “Home health within stay potentially preventable hospitalization” beginning in 2023. 

Case-mix weights adjusted. CMS finalized plans to recalibrate the PDGM case-mix weights, functional levels and comorbidity adjustment subgroups while maintaining the low utilization payment adjustment (LUPA) thresholds for 2022. The changes will reflect data on 30-day periods under PDGM and “more accurately reflect the types of patients currently receiving home health services,” according to CMS.

CoPs changes. CMS is finalizing policies that makes permanent current blanket waivers related to home health aide supervision and the use of telecommunications in conducting assessment visits.

“While we are finalizing the limited use of telecommunications technology when performing the 14-day supervisory visit requirement when a patient is receiving skilled services, we expect that in most instances, the HHAs would plan to conduct the 14-day supervisory assessment during an on-site, in person visit, and that the HHA would use interactive telecommunications systems option only for unplanned occurrences that would otherwise interrupt scheduled in-person visits,” according to the CMS statement.

The new rule updates regulation text to allow Occupation Therapists (OTs) to conduct initial and comprehensive assessments for all Medicare beneficiaries under the home health benefit when the plan of care does not initially include skilled nursing care, but includes either Physical Therapy (PT) or Speech-Language Pathology (SLP).

Occupational Therapy LUPA Add-on Factor. CMS is establishing a LUPA add-on factor for calculating the LUPA add-on payment amount for the first skilled occupational therapy visit in LUPA periods that occurs as the only period of care or the initial 30-day period of care in a sequence of adjacent 30-day periods of care. CMS will utilize the physical therapy LUPA add-on factor as a proxy until CY 2022 data is available to establish  a more accurate occupational therapy add-on factor for the LUPA add-on payment amounts.

Read the full rule: https://public-inspection.federalregister.gov/2021-23993.pdf

Prepare for changes with our upcoming webinar:

HHVBP Bonuses Start With Solid Outcome Scores, Tuesday, Nov. 16.