The uncertainty hovering over the Centers for Medicare and Medicaid Services’ (CMS) Home Health Groupings Model (HHGM) has been cleared—at least for the time being.
CMS issued is final rule for the home health care prospective payment system (PPS) 2018 update in early November without finalizing HHGM.
“CMS is not finalizing the implementation of the Home Health Groupings Model in this final rule,” the agency explained on its website. “The agency received many comments from the public that it would like to take into further consideration.”
Heavy Opposition
More than 1,300 comments were left by stakeholders on the Federal Register during the public comment period, with many stressing to CMS that the rule should be dropped.
In addition to industry insiders, lawmakers advocated on their behalf, with a total of 174 signatories—comprised of 39 Republicans and 99 Democrats from the House of Representatives—who pushed for CMS to “refrain from finalizing the proposed HHGM,” until the impact could be fully understood in an October 25 letter to CMS Administrator Seema Verma.
In its original format, HHGM proposed to replace the current 60-day episode of care with a 30-day payment period and could have slashed as much as $950 million in reimbursement payments to providers in 2019. This would have translated to a significant payment reduction to providers, which different industry groups have estimated at 15% and 17%. Among other aspects, the proposed model would have changed reimbursement rates and incentives for therapy services, reducing care access in the eyes of a number of industry advocates.
On the Table
While CMS may have put HHGM on hold, the final rule did confirm the payment structure for home health reimbursements beginning in 2018.
As part of CMS’ final rule, the agency projects that Medicare payments to home health agencies in calendar year 2018 will be reduced by 0.4%, or $80 million, based on the finalized policies.
This decrease reflects the effects of a 1% home health payment update percentage ($190 million increase); a -0.97% adjustment, or a $170 million decrease, to the national, standardized 60-day episode payment; and the sunset of the rural add-on provision for an impact of -0.5% ($100 million decrease).
The rule also finalizes proposals for the Home Health Value-Based Purchasing (HHVBP) Model and the Home Health Quality Reporting Program (HH QRP).
A Resurgence?
HHGM may be off the docket for now, but it’s not completely off the table, according to CMS.
CMS stated it plans to consider many of the comments on HHGM that were publicly posted on the Federal Register. Namely, CMS noted that commenters were “generally supportive” of revising the case-mix methodology, and were most concerned with the proposed 30-day episode of care—”and such change being proposed for implementation in a non-budget neutral manner.”
CMS also acknowledged the industry’s desire to be more involved in the process, as many industry heavyweights and stakeholders are willing to work alongside the agency in developing a new reimbursement model.
Stay Ahead of Regulations
With a new reimbursement structure in place for 2018, and with various industry regulations on the horizon, home health agencies will have no shortage of challenges over the next year—and should look to their EMR vendor for support.
For more information on how Optima’s home health software can help your agency successfully navigate these changes and ensure compliance, be sure to watch our home health demo.