CMS estimates that 2024 home health payments would decrease in the aggregate by 2.2%, or a $375 million reduction in payments compared to 2023.
 
CMS released its payment projection in the 2024 proposed rule for the Home Health Prospective Payment System Rate Update on Friday, June 30, 2023.
 
The decrease includes a permanent 5.65 percent cut in the national, standardized 30-day period payments as part of behavioral adjustments under PDGM.
 
According to CMS, the overall payment decrease reflects the effects of:
  • A 5.1% decrease based on the permanent behavioral assumption adjustment, including LUPAs (a $870 billion decrease)
  • A proposed increase of 2.7% in the home health payment update percentage (a $460 million increase)
  • An estimated 0.2% increase that reflects the effects of an updated fixed-dollar loss ratio (FDL) used in determining outlier payments (a $35 million increase)
The rule would also:
  • Create two new Home Health Quality Reporting Program (HHQRP) measures: “COVID-19 Vaccine: Percent of Patients Who Are Up to Date” and “Functional Discharge Score.”
  • Remove five and add three quality measures to the Home Health Value-Based Purchasing (HHVBP) model, as well as some weight adjustments.
  • Adjust the baseline year for HHVBP to 2023 starting with the 2025 performance year.
  • Create the Hospice Special Focus Program (SFP) and informal dispute resolution process.
CMS is also seeking comments on questions related to a continued decrease in home health aide services as part of the home health benefit.
 
 
HHVBP changes
 
The rule proposes removing five measures from the Home Health Value-Based Purchasing model, along with associated weight adjustments, beginning in 2025.
 
The changes would align the measures used in the HHVBP model with the measures in the HHQRP, CMS notes in the rule.
 
“This alignment will support comparisons of provider quality and streamline home health providers’ data capture and reporting processes,” CMS states.
 
If finalized, “Change in Mobility” and “Change in Self-Care” would be removed from the OASIS-based measures. They would be replaced with the new “Discharge Function Score” measure proposed for inclusion in the HHQRP. Among the reasons, CMS notes that it’s a single measure reflecting self-care and mobility, as opposed to two separate measures.
 
The rule also would replace “Acute Care Hospitalizations” and “Emergency Department Use Without Hospitalization” with the already collected “Potentially Preventable Hospitalization” measure.
 
“Discharged to Community” would be removed as an OASIS-based measures and it would be added as a claims-based measure.
 
The shift to the claims-based measure will expand the data used from one year to two years, CMS notes. It also aligns risk-adjustment, exclusions and measure intent with other post-acute settings.
 
The changes to the measures also comes with a reweighting of the measures. Changes in the large cohort include:
  • Improvement in Dyspnea will account for 6.00% of the final score, down from the current 8.57% value.
  • Improvement in Management of Oral Medications will account for 9.00%, up from the current 12.86%
  • The new Discharge Function Score will account for 20%
  • The new Potentially Preventable Hospitalization measure will account for 26.00%
  • The new Discharge to Community measure will account for 9%, up from the current 5.83% for the OASIS-based discharge measure.
The rule also would adjust the baseline year for HHVBP adjustments to 2023 starting with the 2025 performance year.
 
COVID-19 vaccination reporting
 
The COVID-19 measure will be based on a new OASIS-E question to be added in 2015: Patient’s COVID-19 vaccination is up to date.
 
The responses would be “0. No, patient is not up to date” or “1. Yes, patient is up to date.” A similar question would be included in patient evaluations at other PAC settings.
 
Agencies would be able to use all sources of information available to obtain the vaccination data, such as patient interviews, medical records, proxy response and vaccination cards provided by the patient/caregivers, according to measure specification published by CMS contractor Abt Associates.
 
“I think the tracking of the COVID-19 vaccination status will become commonplace like the influenza vaccine status,” says Lisa McClammy, senior clinical education consultant with MAC Legacy in Denton, Texas. “We have seen so many changes in our practice related to the COVID-9 pandemic, and tracking vaccination status may help identify trends in COVID-19 cases.”
 
Discharge Function Score
 
CMS also is proposing the addition of a Discharge Funcation Score to the HHQRP beginning in 2025.
 
The function score will determine how successful each agency is at achieving an expected level of function ability for its patients at discharge, according to CMS.
 
The final Discharge Function Score for a given agency is the proportion of its episodes where a patient’s observed discharge score meets or exceeds their expected discharge score, according to measure specifications from Abt Associates. Agencies with low scores are not producing the functional gains that they could be for a larger share of their patients, according to the Abt report.
 
The measure will be calculated entirely using administrative data — no additional data collection or submission requirements are expected.
Functional status is measured through Section GG of OASIS assessments related to self-care (GG0130) and mobility (GG0170).
 
Coefficients from a risk adjustment model controlling for admission function score, age and patient clinical characteristics will be used to determine an expected discharge function score for each home health episode.
 
Hospice Special Focus Program
 
Hospice providers struggling to meet care quality standards will be flagged on Care Compare under the Hospice Special Focus Program (SFP).
 
CMS noted in the hospice proposed rule in March that the SFP was not ready at that time and would be published in the home health rule this summer.