Home Health & Hospice Week

Plus: CMS will allow home infusion therapy back billing in the new year.

In a year of tumult under PDGM and COVID, the new 2021 home health payment final rule is more noted for its lack of help rather than proactive changes. But the regulation released Oct. 29 also contains a number of relatively low-key provisions including:

• OASIS. A change in the Medicare Conditions of Participation governing OASIS transmission testing for new HHAs will give new providers a slight bit of relief. Newbies formerly had to transmit test data and had to use a fake CMS Certification Number (CCN) to do so. Now, the new Internet QIES data submission system won’t accept fake CCNs, so CMS is removing this step.

          When CMS first proposed the change in July, experts said while the change offers only a bit of relief, a little is better than none (see HCW by AAPC, Vol. XXIX, No. 25-26).

• NPPs. COVID-19-related regulations earlier this year allowed nurse practitioners (NPs), clinical nurse specialists (CNSs), and physician assistants (PAs) to “certify, establish and periodically review the plan of care, as well as supervise the provision of items and services for beneficiaries under the Medicare home health benefit,” CMS notes in the final rule. As proposed, the 2021 final rule will make this non-physician practitioner change permanent and implement corresponding regulatory updates.
• Value-Based Purchasing. CMS finalized without change its “policy to align HHVBP Model data submission requirements with any exceptions or extensions granted … during the COVID-19 PHE, as described in the May 2020 COVID-19” interim final rule, the home health final rule says. “We are also finalizing without modification the policy for granting exceptions to the New Measures data reporting requirements under the HHVBP Model during the COVID-19 PHE.”
• HIT. The 59-page rule spends nearly 20 pages outlining the new Home Infusion Therapy benefit. Commenters expressed a number of concerns. One was “the short time frame providers will have to enroll before the program goes into effect on January 1, 2021,” the National Association for Home Care & Hospice says in its member newsletter.

“Home infusion therapy suppliers will be processed as expeditiously as feasible,” CMS assured in the final rule. And regulatory changes “permit home infusion therapy suppliers to back bill for certain services furnished prior to the date on which the MAC approved the supplier’s enrollment application,” CMS adds.