CMS Releases Proposed 2019 HHPSS Update

CMS released its 600-page 2019 Proposed Medicare HHPPS Update at 4:15pm yesterday.  You can download the document at this link: https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-14443.pdf

While it will take a while to digest the entire proposal, below is a list of the basic elements, as sent to State Associations by Bill Dombi, president of NAHC.

2019 Payment rates

  1. The 2019 proposed payment rates increase by 2.1%
  2. The 2019 rural add-on amount depends on whether the HHA is in a frontier area or a high utilization area—234 counties are considered frontier where the ad-on will increase to 4%; 510 counties are high utilization where the add-on will drop to 2%; and the remaining 1162 counties will get 3%.
  3. Outlier eligibility will be slightly tightened with the Fixed Dollar Loss ration dropping to 0.51% from 0.55%.
  4. LUPA stays the same

2020 New Payment Model

  1. CMS proposes a new payment model that looks a lot like HHGM
    1. 30 day payment unit
    2. Therapy thresholds gone
    3. Case mix adjustment model with 216 categories using measures such as “early” or “late: time period; institutional discharge or community admission; 3 functional levels; comorbidity adjustment
    4. “behavioral adjustment to base rates to account for diagnosis coding and visit volume changes (-6.42%)
    5. Budget Neutral rate setting except for behavioral adjustment (combined the proposed 30 day payment unit increases from the 2017 HHGM proposal at just over $1600)
    6. Combined care and non-routine medical supplies
    7. 30 day LUPA ranging from 2-7 visits depending on case mix category
    8. ossible end to RAPs
  2. CMS considers HHA inputs in the changes proposed
  3. CMS does not intend to empanel another TEP (Technical Experts Panel)
  4. Would start on January 1, 2020

Other proposals

  1. New home infusion therapy benefit (21st Century Cures legislation created it)
  2.  Elimination of requirement that certifying physician specifically state how much longer care would be needed
  3. Permit the incorporation of HHA records into physician record including through the use of the Plan of Care
  4. HHVBP demo refinements
  5. OASIS refinements

NAHC will be conducting a deep analysis into this very deep and wide proposed rule. Earlier today, NAHC issued the following statement:

 

 

CMS released today the proposal for 2019 payment rates along with its proposal for the new payment model that would start in 2020. All eyes are on the 2002 proposal. In the 600 page proposed regulation, it appears that the 2020 model is a modestly adjusted and “warmed-over” version of the highly criticized Home Health Groupings Model re-labeled as the Patient-Driven Groupings Model. Many of the same weaknesses present in HHGM exist in this new version.

 

NAHC remains very concerned that the new model still includes a significant “behavioral adjustment” based on assumptions that would trigger a 6.42% reduction in base payment rates. Many of these assumptions are driven by CMS’s design with unnecessary changes to the current model. We do not want to prematurely judge the 2020 version of payment reform as it is complex, detailed, and will require deep analysis. However, we are concerned that CMS may have been relegated to using too much from its HHGM design because CMS is pressed by a deadline. We hope that Congress can recognize the value of providing a more flexible timeframe to CMS.

 

We would note that the draft rule also contains very important other proposals including the implementation of the home infusion therapy benefit and  improvements to the claims processing standards to permit greater inclusion of home health agency records in reviewing eligibility for Medicare benefits.

 

“We will be addressing all of our concerns with CMS through the rulemaking process and enlisting Congressional support as needed to develop reasonable payment reform,” stated Bill Dombi, NAHC President. “These proposals represent some of the most significant change in the home health payment system in nearly 20 years. They warrant close and critical review by the industry before any judgment is made. Still, an early review indicates that the proposed system needs more work,” he added.  .