The final rule for the 2018 Home Health Prospective Payment (CMS-1672-F) has been issued by the Centers for Medicare & Medicaid Services (CMS). The most significant omission from the proposed rule released in July is the proposal for a new payment model in 2019 known as Home Health Groupings Model (HHGM). The HHGM would use 30-day periods instead of 60-day episodes used in the current payment system, eliminate the use of the number of therapy visits to determine payment, and rely more heavily on clinical characteristics and other patient information for payment. Industry experts estimated this system as proposed would have resulted in at least a 4.3 percent reduction in overall reimbursements and lead to the closing of many agencies.
CMS has indicated they are not finalizing HHGM at this time and will “take additional time to further engage with stakeholders to move towards a system that shifts the focus from volume of services to a more patient-centered model. CMS will take the comments submitted on the proposed rule into further consideration regarding patients’ needs that strikes the right balance in putting patients first.”
A full review of the rationale provided in the final rule shows this is not a full withdrawal of the proposal, but rather an opportunity for further engagement by stakeholders (home health agencies, state and national home health associations, etc.) who have worked to influence the implementation of the payment model or its elimination. The Texas Association of Home Care & Hospice (TAHCH) shared “that legislation is being considered that would codify aspects of HHGM [and TAHCH is working] with members of the Ways and Means committee to ensure that if any legislation moves forward that it will ensure the viability of the industry.”
There a number of other items of note in the 2018 Home Health Final Rule such as changes to the Home Health Value-Based Purchasing (HHVBP) Model and the Home Health Quality Reporting Program (HHQRP) which we will review in future blogs.
The 2018 Home Health Prospective Payment System Rate Update can be found here.
The CMS rule fact sheet can be found here.