CMS Releases Proposed 2015 PPS Changes

Centers for Medicare and Medicaid Services (CMS) posted the new proposed PPS changes that include changes for 2015 and introducing 2016 roll-out of Home Health (HH) Value-based Purchasing Model. Comment period is open from July 7 until September 2, 2014.

2015 Medicare Home Health PPS Proposal from CMS

CMS has proposed eliminating the brief narrative required as part of the physician F2F encounter. This huge victory for home health agencies and physicians is a testament to the persistence of industry advocates voicing our concerns. New Hampshire’s health care providers suggested in a letter to CMS last month the the F2F encounter will still need to occur and be documented, and that is what CMS has proposed. Comments on the proposal are due to CMS by September 2. The final rule will take effect January 1, 2015.

Below is a quick overview of what is contained within the rule:
  • 2015 Home Health Prospective Payment System rates that reduce rates under the 4-year rebasing
  • Face-to-Face Physician Encounter rule modifications including the elimination of the physician narrative requirement
  • Significant change to the requirement for professional therapy reassessments, dropping the 13th and 19th visit requirements and instituting a 14 day reassessment standard
  • HH Quality Reporting – A new numerical standard for the submission of OASIS to avoid payment rate reductions
  • Therapy reassessment simplification- Modifications of the standards for qualification of speech-language pathologists under the CoPs
  • HH PPS Case-Mix Weights; Wage Index; Market Basket Adjustments; & Rebasing rate
  • The introduction of possible new, restrictive coverage standards on the administration of insulin injections
  • 2016 HH Value-based Purchasing Model  The unveiling of a likely model for Value Based Purchasing that would be mandatory in 5-8 undesignated states
  • Clarifications of the requirements for imposition of alternative Civil Money Penalty sanctions for CoP violations
  • Changes to re-certification requirements

To review the proposal in its entirety, go to: http://www.gpo.gov/fdsys/pkg/FR-2014-07-07/pdf/2014-15736.pdf

Starting on July 7, you can review and comment on the proposed changes online at http://federalregister.gov/a/2014-15736. Comment period ends September 2, 2014.

VNAA Filed Comments

On Monday, the Visiting Nurse Associations of America filed comments with the Centers for Medicare and Medicaid Services regarding the proposed FY15 Payment Rule for Hospice. The comment letter was crafted with significant member input and is available on the VNAA website. The letter details a number of VNAA’s concerns and proposed solutions on a wide variety of issues impacting hospice and palliative care reimbursement including payment reform, quality measures, Part D drug provisions and more. VNAA made hospice advocacy a top policy priority for 2014 and this letter is a significant document for that organization.

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