Home Health & Hospice Week

Cap on wage index swings looks likely to be part of HH rule, too.

With so many things on your plate, it’s easy to let something without an immediate direct reimbursement impact go by the wayside. But that would be a mistake.

The Centers for Medicare & Medicaid Services will take comments on its 2023 proposed rule on hospice payment and quality until May 31, CMS notes on its website. The rule contains proposals for a 2.7 percent rate increase, a permanent 5 percent cap on negative wage index changes, an updated timeline for the Special Focus Program and other survey revisions, and various quality provisions (see HCW by AAPC, Vol. XXXI, Nos. 12 and 13 for more rule details.)

“We encourage you to review the rule, and submit formal comments by May 31, 2022,” CMS says on its website.

Meanwhile, CMS has since proposed the same 5 percent cap on negative wage index swings in other 2023 provider rules, including the one for the inpatient prospective payment system (IPPS) for hospitals. That seems a strong indicator that it will show up in the home health rule as well.

The cap’s impact on hospitals will be very similar to the one on home health and hospice agencies.

“CMS finally acknowledges that it is difficult for hospitals to plan when the wage index values can change drastically,” notes consultant Sue Brammer with BKD in Kansas City, Mo., in online analysis. “Implementing this policy will likely eliminate further guardrails in FFY 2024 when the full impact of the pandemic is included in the wage index,” she adds. And “similarly, when future census changes are incorporated, CMS noted the 5 percent cap would eliminate the need for special provisions,” she says.

The hospice rule, including instructions for submitting comments, is at www.govinfo.gov/content/pkg/FR-2022- 04-04/pdf/2022-07030.pdf.