Here are some home health related updates for this week:
Meet us at Home Care Association of Florida 32nd Annual Conference
Amity is excited to announce that we will be participating in Home Care Association of Florida 32nd Annual Conference & Trade Show that will be held in Orlando, Florida July 20-23, 2021.
If you are planning on attending this event, please take a minute and stop by booth #101 in the Exhibitor’s Hall July 21st and July 22nd. We will be looking forward to meeting you.
In addition, Irina Gorovaya will also be presenting on the topic of Practical Guide to Home Health Competency Program on July 22, 21 at 10 am ET in Meyer 2 Room.
Amity Healthcare Group Consulting Services
Amity Healthcare Group is providing continuous support to home health providers in the following areas:
- Medicare Certification/Accreditation Survey preparation
- Regulatory and clinical compliance review
- QAPI implementation and analysis
- Emergency Preparedness
If you need assistance with any of the above, please call us 303-690-2749 to schedule your 30-minute free consultation.
CY2022 Home Health Proposed Final Rule
As you may know, on June 28, 2021, CMS released CY2022 Home Health Proposed Final Rule. Below, you will find the summary of the proposed changes. In the future newsletters, we will be discussing each of the proposed areas in more details:
Proposed Home Health Value-Based Purchasing (HHVBP) Model Expansion
CMS implemented the HHVBP Model on January 1, 2016 to test whether payment incentives can generate a change in health care providers’ behavior to improve quality of care, through payment adjustments based on quality performance. At this time, HHVBP is being applied to all Medicare-certified Home Health Agencies providing services in Arizona, Florida, Iowa, Maryland, Massachusetts, Nebraska, North Carolina, Tennessee, and Washington.
CMS is proposing to expand the HHVBP Model nationwide effective January 1, 2022. The first performance year of the expanded HHVBP Model would be CY 2022, with quality performance data from that year used to calculate payment adjustments under the expanded Model in CY 2024.
CY 2022 Proposed Payment Updates
CMS estimates that Medicare payments to HHAs in CY 2022 would increase in the aggregate by 1.7 percent, or $310 million, based on the proposed policies.
Patient-Driven Groupings Model (PDGM) and Behavioral Assumptions
The proposed rule provides preliminary analyses of the first year of the PDGM including data on admission source, timing, clinical grouping, functional impairment level, comorbidity adjustment and the provision of therapy visits (physical, occupational, and speech). Additionally, CMS provides a detailed method on how it analyzed the difference between assumed and actual behavior changes. CMS is not proposing any specific method or behavior assumption payment adjustment in this proposed rule, but rather is seeking for comments to determine the impact of behavior changes on estimated aggregate expenditures.
Recalibration of PDGM Case-Mix Weights
CMS is proposing to adjust the case-mix weights, functional levels, and comorbidity adjustment subgroups using CY 2020 data to more accurately pay for the types of patients HHAs are serving. Additionally, CMS is proposing to maintain the CY 2021 LUPA thresholds for CY 2022.
Home Health Conditions of Participation
CMS is proposing to make permanent selected regulatory blanket waivers related to home health aide supervision and the use of telecommunication that were issued to Medicare participating home health agencies during the COVID-19 public health emergency (PHE). The proposal comes with a stipulation that CMS will expect that in most instances, the HHAs would plan to conduct the 14-day supervisory assessment during an on-site, in person visit, and that the HHA would use interactive telecommunications systems option only for unplanned occurrences that would otherwise interrupt scheduled in-person visits.
CMS is also proposing to update the home health Conditions of Participation to permit an occupational therapist to conduct the initial assessment visit and complete the comprehensive assessment under the Medicare program, but only when occupational therapy is on the home health plan of care with either physical therapy or speech therapy and skilled nursing services are not initially on the plan of care.
Occupational Therapy LUPA Add-on Factor
In the light of the proposal to allow Occupation Therapists (OTs) to conduct initial and comprehensive assessments for all Medicare beneficiaries under the home health benefit when the plan of care does not initially include skilled nursing care, but includes either Physical Therapy (PT) or speech-language pathology (SLP), CMS also is suggesting to establish a LUPA add-on factor for calculating the LUPA add-on payment amount for the first skilled occupational therapy visit in LUPA periods that occurs as the only period of care or the initial 30-day period of care in a sequence of adjacent 30-day periods of care.
Proposals and Updates to the Home Infusion Therapy Benefit for CY 2022
CMS is proposing to update the home infusion therapy services payment rates for CY 2022 as required by law based on the percentage increase in the consumer price index for all urban consumers (CPI-U) reduced by the productivity adjustment for CY 2022.
Home Health Quality Reporting Program
The HH QRP is a pay-for-reporting program. HHAs that do not meet reporting requirements must be subject to a two-percentage point (2%) reduction in their annual update. In addition, changes in several quality measures were also proposed.
Closing the Health Equity Gap – RFI
CMS is exploring opportunities to address the inequities in health outcomes through improving data collection to better measure and analyze disparities across its programs and policies. As the result, CMS is seeking feedback in this RFI on ways to attain health equity for all patients through policy solutions and the possibility of expanding measure development, and the collection of other standardized patient assessment data elements that address gaps in health equity in the HH QRP.
As the result, CMS is proposing that in supporting the coordination of care, HHAs begin collecting data on the Transfer of Health Information to Provider-Post Acute Care measure, the Transfer of Health Information to Patient-PAC measure, as well as six categories of standardized patient assessment data elements effective January 1, 2023 (OASIS E) to position itself with data to monitor outcomes across diverse populations.
Updated Emergency Preparedness Guidance
CMS has released revised emergency preparedness (EP) guidance for surveyors, as well as providers and suppliers, with assessing a facility’s compliance with the EP requirements.
The revision targets the area of Emergency Preparedness Training and Testing program requirements and exemption criteria and is primarily addresses guidance for inpatient facilities. What concerns outpatient facilities (home health), the providers must still conduct annual testing – a full-scale exercise (or individual facility-based exercise when a full-scale is not available) every two years and in opposite years conduct any one of the “exercises of choice,” which include another full-scale or individual facility-based functional exercise, table top exercise, workshop, or mock drill. To summarize, home health providers are required to conduct one annual exercise- alternating full-scale and exercise of choice. Home Health providers will be expected to continue following the guidance issued in 2019, as the facility was either exempt from the full-scale exercise in 2020 or in 2021, depending on its cycle of testing exercises.
Example: Facility Y conducted a table top exercise in January 2019 as the exercise of choice and conducted a full-scale exercise in January 2020. In March 2020, Facility Y activates its emergency preparedness program due to the COVID-19 PHE. The facility is exempt from the January 2022 full-scale exercise for that “annual year”. However, the facility must conduct its exercise of choice by January 2021, and again in January 2023.
For a complete EP guidance, please go to: https://www.cms.gov/files/document/qso-20-41-all-revised-06212021.pdf
Provider Relief Funds Reporting
The Provider Relief Fund (PRF) Reporting Portal is now open for providers who need to report on the use of funds in Reporting Period 1.
Providers who are required to report during Reporting Period 1 have until September 30, 2021 to enter the Portal and submit their information.
Please remember that providers who received one or more payments exceeding $10,000, in the aggregate, during a Payment Received Period are required to report in each applicable Reporting Time Period. PRF recipients must only use payments for eligible expenses, including services rendered, and lost revenues attributable to coronavirus before the deadline that corresponds to the relevant Payment Received Period.
FAQs: Since June 11, 2021, HHS released updated PRF FAQs which you can read here.
Additional resources: you can find the following resources on the Provider Relief Reporting Portal at https://prfreporting.hrsa.gov/s/
Home Health Quality Reporting Program updates
Just a reminder that CMS will be removing five quality measures from home health Care Compare in late July of 2021. The five quality measures are:
- Depression Assessment Conducted
- Diabetic Foot Care and Patient/Caregiver Education Implemented During All Episodes of Care,
- Multifactor Falls Risk Assessment Conducted for All Patient Who Can Ambulate
- Pneumococcal Polysaccharide Vaccine Ever Received
- Improvement In Status of Surgical Wounds
Review Choice Demonstration for Florida and North Carolina extended
On June 30, 2021, CMS will be extending the phased-in participation of the Review Choice Demonstration for Home Health Agencies in Florida and North Carolina until 7/31/21.
- Providers may continue submitting pre-claim review requests.
- Claims that go through pre-claim review and are submitted with a valid UTN will be excluded from further medical review.
- Claims submitted without going through the pre-claim review process will process as normal and will not be subject to a 25% payment reduction. These claims may be subject to post-payment review in the future through the normal medical review process.
Health First Colorado Provider Rate Increase
Heath First Colorado announced provider rate increase that will be effective for dates of service beginning July 1, 2021. All rate adjustments are subject to Centers for Medicare & Medicaid Services (CMS) approval prior to implementation. The fee schedules can be located on the Provider Rates & Fee Schedule web page and have been updated to reflect the approved 2.5% across-the-board rate increases (rate increase applies to Acute and Long Term Home Health and PDN). Rates will be updated in the Colorado interChange once approval is received from CMS.
Please note: when rate increases are implemented, claims that were already billed and paid at a rate lower than the new rate cannot be adjusted for the higher rate. The “lower of” pricing logic is always used.
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Irina Gorovaya, RN BSN, MBA
Amity Healthcare Group, LLC
Home Health Consulting, Education and Outsourcing Services
720-353-7249 (cell) 303-690-2749 (office) 720-398-6200 (fax)