BriggsNetNews

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

The calendar year 2023 Home Health Prospective Payment System Final Rule was published on October 31, 2022. The following are the Home Health Quality Reporting Program proposals have been finalized: CMS finalized a proposal to end the suspension of the collection of Outcome and Assessment Information Set (OASIS) data on non-Medicare/non-Medicaid patients under section 704 of the Medicare Prescription Drug, Improvement, and Modernization Act of 2003, and to require HHAs to report all-payer OASIS data for purposes of the HH QRP, beginning January 1, 2025.  CMS has also finalized updates to regulatory text to consolidate statutory references to data submission and to codify in regulations the HH QRP measure removal factors previously finalized via rulemaking.

The HH PPS Final Rule (232 pages) is available at https://public-inspection.federalregister.gov/2022-23722.pdf.

Below is one of the tables from the HH PPS Final Rule, specifically addressing estimated clinician costs for completion of the OASIS-E:

CMS also posted this Fact Sheet on Monday.  Please be sure to review the Final Rule as well as the Fact Sheet for information about:

• Finalizing recalibration of the PDGM case-mix weights;
• Updates the low utilization payment adjustment (LUPA) thresholds, functional impairment levels, comorbidity adjustment subgroups for CY 2023, and the FDL used for outlier payments;
• Finalizes the reassignment of certain diagnosis codes under the PDGM case-mix groups;
• The PDGM better aligns payments with patient care needs, especially for clinically complex beneficiaries that require more skilled nursing care rather than therapy;
• Finalizing a -3.925% permanent adjustment to the 30-day payment rate in CY 2023 to ensure that aggregate expenditures under the new payment system (PDGM) would be equal to what they would have been under the old payment system. The remaining permanent adjustment, along with any other potential adjustments needed to the base payment rate to account for behavior change based on data analysis, which are all required by law, will be proposed in future rulemaking;
• Finalizes a permanent, budget neutral 5% cap on negative wage index changes (regardless of the underlying reason for the decrease) for home health agencies to smooth year-to-year changes in the pre-floor/pre-reclassified hospital wage index;
• Finalizing recalibration of the case-mix weights (including the functional levels and comorbidity adjustment subgroups) and LUPA thresholds using CY 2021 data to more accurately pay for the types of patients HHAs are serving;
• Finalized policy changes regarding the use of services furnished via telecommunications systems in the CY 2021 HH PPS final rule;
• Comment Solicitation on the Collection of Data on the Use of Telecommunications Technology under the Medicare Home Health Benefit;
• Updates to the Home Infusion Therapy Benefit for CY 2023;
• CMS is ending the temporary suspension of OASIS data collection on non-Medicare/non-Medicaid HHA patients. HHAs will be required to submit all-payer OASIS data for purposes of the HH Quality Reporting Program (QRP) beginning with the CY 2027 program year, with two quarters of data required for that program year. We are finalizing a phase-in period for January 1, 2025 through June 30, 2025, in which failure to submit the data will not result in a penalty;
• Health Equity Request for Information (RFI) – comments received and
• Baseline Years in the Expanded Home Health Value-Based Purchasing (HHVBP) Model
  • Add definitions for HHA baseline year and Model baseline year, and remove the previous definition of baseline year;
  • Change the HHA baseline year from CY 2019 to CY 2022 for existing HHAs with a Medicare certification date prior to January 1, 2019, and from 2021 to 2022 for HHAs with a Medicare certification date prior to January 1, 2022 starting in the CY 2023 performance year and
  • Change the Model baseline year from CY 2019 to CY 2022 starting in CY 2023.