Home Health & Hospice Week

Home care expertise goes to waste in final joint replacement bundling methodology.

The imminent Comprehensive Care for Joint Replacement Model, which will adjust hospital payments based partly on home health spending for the patient, is creating new care procedures for home care providers — but not too new.

As part of the CJR proposed rule issued last April, the Centers for Medicare & Medicaid Services floated the idea of Medicare paying for up to nine physician post-discharge home visits to non-homebound LEJR patients during each 90-day post-anchor hospitalization CJR episode. The visits would include a direct physician supervision waiver, allowing clinical “auxiliary staff” to perform the visits. “The waiver would not apply with respect to a CJR beneficiary who has qualified, or would qualify, for home health services when the visit was furnished,” CMS clarified in the rule.

On one hand: In their comment letters, docs asked for the ability to furnish such services under the waiver whether the patient would qualify for home care or not.

On the other hand: Many home care commenters asked CMS for the ability for HHAs to furnish those nine post-discharge visits to non-homebound patients under the program. After all, home care visits are their specialty.

CMS shot down the requests from both sides and finalized the proposal as-is. “We believe the ‘incident to’ relationship of post-discharge home visits to a physician’s professional services is critical due to the importance of robust care coordination and close care management to episode cost and quality performance, given the lengthy, broadly defined CJR episodes,” CMS maintains in the final rule.

“The limited waiver of only the direct physician supervision requirement for ‘incident to’ post-discharge home visits that we are providing under the CJR model will be sufficient,” CMS concludes.