Home Health & Hospice Week

Prospective Payment System:

Say Goodbye To Therapy, 60-Day Episodes Under PPS Payment Reform

CMS may take the next step as soon as this summer, expert predicts.

Medicare’s plan to significantly revamp home health agency payments continues to gain steam — and now you may get an inkling of whether the new system will leave you tied to the tracks.

As promised in the 2017 Home Health Payment System final rule and in an August Open Door Forum outlining the reform plan, Centers for Medicare & Medicaid Services PPS reform contractor Abt Associates has issued a technical report on the Home Health Groupings Model refinement, titled “Medicare Home Health Prospective Payment

System: Case-Mix Methodology Refinements — Overview of the Home Health Groupings Model.”

The report doesn’t appear to contain any big surprises, but does go into more detail on many of the case mix changes outlined in the previous forum (see Eli’s HCW, Vol. XXV, No. 32), including:

  • dropping therapy utilization from the case mix equation altogether;
  • shortening PPS episodes to 30 days, with only the first episode counted as “early;”
  • adjusting rates based on source of admission within the last 14 days — institution versus community;
  • adjusting rates by placing patients into six clinical groups: musculoskeletal rehabilitation; neuro/stroke rehabilitation; wounds; medication management, teaching, and assessment; behavioural health; or complex nursing interventions; and
  • adjusting rates by placing patients into two or three functional groups, depending on clinical group.

More details: Back in August, Abt said it still hadn’t nailed down how it would use another PPS case mix factor for comorbidities. But now it outlines adjustments based on two groups, “yes” or “no,” utilizing secondary diagnoses.

Timeline Still Unclear

Neither the 2017 final rule, Open Door Forum presentation, nor this technical report lay out any timeline for payment reform implementation. And CMS did not respond to inquiries about the timeline by press time.

“CMS has not given even a hint about its timeline,” William Dombi, VP for law with the National Association for Home Care & Hospice, tells Eli.

Stay tuned: “My best guess would be that we may see something in the 2018 rulemaking with a June/July 2017 proposed rule,” Dombi predicts. And the reform plan likely falls too far down the food chain to see any impact from the changing political climate at CMS and/or the Department of Health and Human Services. “I do not see this detoured by the new administration,” Dombi says.

Note: See the 178-page report, with many details about how episodes would be grouped based on specific diagnosis codes, OASIS responses, etc., at https://downloads.cms.gov/files/hhgm technical report 120516 sxf.pdf. And stay tuned to Eli’s Home Care Week for further analysis of the potential payment revamp plan.

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