CMS is standing strong on plans to reduce home health reimbursement by just a fraction and to remove the narrative requirement for physician face-to-face visits. But one major change in the final 2015 PPS rule is that therapy reassessments need to take place every 30 calendar days, rather than every 14 calendar days as proposed in July.
 
The final 2015 PPS rule, released today, reduces overall Medicare reimbursement by $60 million, or 0.30%. The calculations don't include the 2% sequestration reduction currently in effect through March 2015 for all Medicare providers.
 
In addition to the reimbursement changes, CMS finalized that physicians no longer need to provide a narrative in their own words explaining why the patient is eligible for home health. The certifying physician still would be required to certify that a face-to-face patient encounter occurred and to document the date of the encounter.
 
"For medical review purposes, we will require documentation in the certifying physician's medical records and/or the acute/post-acute care facility's medical records (if the patient was directly admitted to home health) to be used as the basis for certification of patient eligibility," CMS says.
 
CMS also finalized that if an agency's claim is denied, the corresponding physician claim for certifying/re-certifying patient eligibility for home health is considered non-covered as well. That's because, CMS says, there is no longer a corresponding claim for Medicare-covered home health services.
 
Also, CMS clarified that face-to-face encounters are required for certifications rather than initial episodes — and that certifications are generally considered any time a new start-of-care assessment is conducted to initiate patient care.
 
Some commenters had urged CMS to entirely eliminate the face-to-face requirement. But within the final rule, CMS said it doesn't have legal authority to do so. The Affordable Care Act, CMS says, requires that prior to certifying a patient's eligibility for Medicare home health, the physician must document that he or an allowed non-physician practitioner had a face-to-face encounter with the patient.
 
Several commenters also wanted CMS to halt medical review activities regarding face-to-face narratives. They wanted CMS to reopen past denials that contractors deemed to have insufficient information within narratives. They wanted the elimination of narratives to be retroactive. But CMS says changes finalized within the rule will become effective for episodes beginning Jan. 1.
 
CMS received 337 comments from agencies, trade associations, individual registered nurses, physicians, clinicians, therapists, therapy assistants, health care industry organizations and health care consulting firms.
 
More changes in final PPS rule
 
  • Therapy reassessment timeframes. Every 30 calendar days, CMS will require a qualified therapist, not an assistant, to provide the needed therapy service and functionally reassess the patient, CMS says in the final rule. Where more than one discipline of therapy is being provided, a qualified therapist from each of the disciplines must provide the needed therapy service and functionally reassess the patient at least every 30 days.
  • Home Health Quality Reporting Program update. CMS would establish a minimum submission threshold for the number of OASIS assessments that each agency must submit. Beginning in CY 2015, the initial compliance threshold would be 70% and will increase by10% increments over the next two years to reach a maximum threshold of 90%.
  • ​Case-mix weight. CMS is finalizing its plans to remove case-mix values from commonly assigned pulmonary, psych 1, psych 2 and blindness/low vision diagnosis categories and two OASIS items will lose their case-mix value. The federal Medicare agency will recalibrate the case-mix weights every year with more current data and continue to monitor case-mix growth to consider whether future reductions are necessary.
  • ​Speech language pathologists. CMS has revised the conditions of participation (CoP) for speech language pathologist (SLP) personnel by replacing current stringent requirements with a more flexible option that defers to state-licensure requirements.
  • ​Value-based purchasing. The home health model being considered would include a 5% to 8% adjustment in payment made after each planned performance period in the projected five to eight states selected to participate in the model.
Training opportunity: Get complete details on the final rule and how it impacts you by signing up for HHL's webinar PPS final rule: Comply with face-to-face, case-mix changes. Sign up at: http://www.decisionhealth.com/conferences/A2558.
 
Related links: For continued, in-depth analysis of how this rule affects your agency, go to www.homehealthline.com. To view the complete rule, visit: http://www.ofr.gov/OFRUpload/OFRData/2014-26057_PI.pdf.