The Center for Medicare and Medicaid Services (CMS) published the Home Health PPS Final Rule on November 3, 2016. The Final Rule defines many changes in effect January 1, 2017. These changes include payment rates, HHRG Case Mix Weight recalibration, updates to the Home Health Value-Based Purchasing pilot program, and implements the coverage for Negative Pressure Wound Treatment using disposable systems.
The following is a summary of the major components of the Final Rule to help guide your internal analysis on how the Final Rule may affect your agency.
Base Payment Rates
Updates for both the per visit and standard episode payment rate, along with non-routine supply rates, as occurs with each year’s update to Home Health PPS. There are several changes to the base rates that can be found in the Final Rule.
The changes to the outlier payment standards are as follows:
- The new formula for outlier calculation takes into account not only the number of visits but the amount of time spent on the visit.
- The new formula is now a cost-per-unit approach instead of cost-per-visit. The calculation will be based on a change to 15-minute increments by discipline.
- In addition, there will be a cap placed for no more than 8 hours (or 32 units) of care per day for all disciplines combined.
When more than one discipline of care is provided and there is more than 8 hours of care provided in one day, the episode cost will be calculated using a hierarchical method based on cost per unit per discipline and the higher rate services are paid before the lower rate services.
The 3% Rural Add-On continues in 2017, along with the 2% rate reduction for home health agencies that do not comply with the quality data submission requirements for OASIS and HH-CAHPS.
Negative Pressure Wound Treatments (NPWT)
The changes for payment made related to NPWT using a disposable device are as follows:
- The disposable NPWT device is intended to substitute for DME-related NPWT.
- Disposable NPWT is now covered by Medicare.
- CMS determined that, since it could be done as outpatient when it is done by home health, it will not be covered by the Medicare Home Health benefit. However, if the patient meets the requirements for home health, it may be done by a SN (RN or LPN), PT or OT but the home health agency will need to bill it as an outpatient procedure.
- The patient has to have Medicare Part B to cover an outpatient procedure and pay for 20% of the cost of the procedure. Because disposable NPWT is an outpatient procedure, the wound assessment, dressing change, and patient education are all considered part of the procedure (not a home health skill).
- CMS has clarified that billing for the NPWT disposable device on a TOB 34x is when the HHA “furnishes NPWT using a disposable device” to mean the provider is either initially applying an entirely new disposable NPWT device, or removing a disposable NPWT device and replacing it with an entirely new one.
- Any follow-up visit related to the wound care where the device is not replaced are to be billed as home health visits on TOB 32x.
- If both a follow-up visit and furnishing of the NPWT disposable device were performed, the home health provider would bill home health visits on TOB 32x and the furnishing of NPWT on the TOB 34x.
This will mean a Medicare Part B payment for the NPWT visits and a LUPA or full episode payment for the other services.
The NPWT professional services will also not count towards the four visit LUPA threshold.
Updates to the Home Health Quality Reporting Program (HHQRP)
CMS proposed to add four new measures, which were developed to meet the requirements of the IMPACT Act.
- MSPB–PAC HH QRP;
- Discharge to Community-PAC HH QRP;
- Potentially Preventable 30-Day Post-Discharge Readmission Measure for HH QRP; and
- Drug Regimen Review Conducted with Follow-Up for Identified Issues-PAC HH QRP
Home Health Value-Based Purchasing Pilot Program
- Benchmarks and achievement thresholds are to be calculated at the state level.
- A minimum of eight home health agencies are now required in any size cohort.
- The time frame for submitting New Measure data has increased from seven to fifteen calendar days following the end of each reporting period to account for weekends and holidays.
- Four measure were removed from the set of applicable measures:
- Care Management: Types and Sources of Assistance
- Prior Functioning ADL/IADL
- Influenza Vaccine Data Collection Period
- Reason Pneumococcal Vaccine Not Received
- The reporting period and submission date adjustment for the Influenza Vaccination Coverage for Home Health Personnel measure from quarterly to annual submission.
- Implementation of the appeal processes.
How will the changes in the CY2017 Home Health PPS Final Rule affect your agency?