Home Health & Hospice Week

Change could lead to more accurate profit margin figures.

Payment reform and rate increases may be grabbing most of the spotlight in the 2019 Home Health Prospective Payment System proposed rule, but there are plenty of other changes afoot as well.

Take a look at some additional provisions in the rule published in the July 12 Federal Register:

• Remote monitoring. Medicare may get a step closer to paying for telehealth with a new provision in the rule. The Centers for Medicare & Medicaid Services notes that “an HHA is not prevented from providing services via a telecommunications system, assuming the service is not considered a home health visit for purposes of eligibility or payment.”

CMS allows that “remote patient monitoring could be beneficial in augmenting the home health services outlined in the patient’s plan of care, without replicating or replacing home health visits.” And “the expenses of remote patient monitoring, if used by the HHA to augment the care planning process, must be reported on the cost report as allowable administrative costs (that is, operating expenses) that are factored into the costs per visit,” CMS adds.

“We propose to amend the regulations at 42 CFR 409.46 to include the costs of remote patient monitoring as an allowable administrative cost (that is, operating expense), if remote patient monitoring is used by the HHA to augment the care planning process. This would allow HHAs to report the costs of remote patient monitoring on the HHA cost report as part of their operating expenses,” according to the rule. “These costs would then be factored into the costs per visit. Factoring the costs associated with remote patient monitoring into the costs per visit has important implications for assessing home health costs relevant to payment, including HHA Medicare margin calculations.”

Good news: “Seeing a proposed allowance for remote patient monitoring costs is very positive, as this has been a sore point for the industry for many years,” notes M. Aaron Little with BKD in Springfield, Missouri.

• Home infusion. For calendar years 2019 and 2020, as required by the Bipartisan Budget Act of 2018, CMS proposes a “temporary transitional payment for home infusion therapy services” that would begin on Jan. 1, 2019 and end the day before the full implementation of the new home infusion therapy benefit, CMS notes in a fact sheet about the rule.

Reminder: The 21st Century Cures Act creates a new separate Medicare benefit category for coverage of home infusion therapy services including associated professional services for administering certain drugs and biologicals through a durable medical infusion pump, training and education, and remote monitoring and monitoring services effective Jan. 1, 2021, CMS notes.

The rule solicits comments on elements of the home infusion therapy benefit; proposes health and safety standards for home infusion therapy; and proposes an accreditation process for home infusion therapy suppliers and an approval and oversight process for the organizations that accredit them.

• VBP. For the Value-Based Purchasing program running in nine states, CMS proposes to remove two OASIS-based measures — Influenza Immunization Received for Current Flu Season Measure and the Pneumococcal Polysaccharide Vaccine Ever Received, from the VBP set; replace three OASIS-based measures with two proposed composite measures on total change in self-care and mobility; amend how the Total Performance Scores are calculated by changing the weighting methodology for the OASIS-based, claims-based, and Home Health CAHPS measures; and rescore the maximum amount of improvement points.
• Electronic records. As with the hospice proposed rule for 2019, CMS is soliciting ideas for “positive solutions to better achieve interoperability or the sharing of healthcare data between providers,” the fact sheet notes. CMS raises the idea of revising the “Conditions of Participation related to interoperability as a way to increase electronic sharing of data by providers. This will inform next steps to advance this critical initiative.”