Home health reimbursement would drop by a fraction, but agencies would gain considerable face-to-face relief under the PPS rule CMS is proposing for calendar year 2015.
As announced July 1, the rule anticipates a 2.2% inflation update offset by the second year of rebasing adjustment to the standardized 60-day episode rate, LUPA rates and rates for non-routine medical supplies. The net effect would be a $58 million, or 0.30%, cut in Medicare payments. 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 is proposing the following to the face-to-face encounter requirements:
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Eliminate the controversial requirement that certifying physicians 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.
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Limit medical reviews to medical records from the patient’s certifying physician or from the discharging facility when determining initial eligibility for the home health benefit.
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Disallow certification and re-certification claims by physicians when the agency claim is denied on grounds that the patient was ineligible for home health.
CMS also clarified that the face-to-face encounter requirement applies to the physician’s certification only, not the re-certification of eligibility for subsequent episodes.
More proposed changes:
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Case-mix weight. CMS proposes to recalibrate case-mix weights using the most current cost and utilization data.
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Therapy reassessment timeframes. Therapy reassessments would occur every 14 calendar days rather than before the 14th and 20th visits and once every 30 calendar days.
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Quality reporting and OASIS submission requirements. 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%.
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Speech language pathologists. CMS is proposing to revise the Home Health Conditions of Participation (CoPs) for speech language pathologist (SLP) personnel by replacing current stringent requirements with a more flexible option that defers to state-licensure requirements.
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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. — Burt Schorr (bschorr@decisionhealth.com)