Home Health & Hospice Week

The voluminous 531-page 2024 home health final rule contains a number of big changes ranging from behavior adjustment cuts to the hospice Special Focus Program. Don’t overlook these additional provisions:

• Home health aide services. The rule includes a discussion on the comments received regarding access to home health aide services, as solicited by the Centers for Medicare & Medicaid Services. “The feedback provided by respondents will help guide our policy formulation processes, and we are hopeful this information can assist in refining policy development, addressing barriers, and fostering coordination under the home health benefit for future regulatory updates,” CMS says in its rule fact sheet.
• Health equity. CMS references health equity in multiple sections of the rule, including the Value-Based Purchasing and Home Health Quality Reporting Program areas. “We are committed to developing approaches to meaningfully incorporate the advancement of health equity into the expanded HHVBP Model,” CMS says in the rule released on Nov. 1.
• dNPWT. As required by the Consolidated Appropri­ations Act (CAA), 2023, “CMS is finalizing its proposal to codify statutory requirements for negative pressure wound therapy (NPWT) using a disposable device for patients under a home health plan of care,” the Centers for Medicare & Medicaid Services says in its rule fact sheet. Beginning Jan. 1, “there is a separate payment for the device only. Payment for the services to apply the device is to be included in the 30-day payment under the home health prospective payment system,” CMS explains. “There are also changes that allow HHAs to now report the disposable device on the type of home health claim most familiar to HHAs,” i.e., TOB 32x.

“Claims with a date of service on or after January 1, 2024 for an applicable dNPWT device will no longer be submitted on TOB 34x,” the National Association for Home Care & Hospice clarifies in its rule summary. Stay tuned for specific billing instructions.

• IVIG. The CAA, 2023 also requires CMS to implement permanent coverage and payment of items and services related to administration of Home Intravenous Immune Globulin in a patient’s home when they have a diagnosed primary immune deficiency disease (PIDD), CMS says in its fact sheet. Currently, Medicare pays for the IVIG product using the average sales price (ASP) methodology, and the items and services under a Medicare Demonstration program. This demo will end on Dec. 31, and permanent coverage and payment of the items and services will begin on Jan. 1, 2024.
• Lymphedema supplies. CAA, 2023 also establishes “a Medicare Part B benefit for standard and custom-fitted gradient compression garments and other compression treatment items for the treatment of lymphedema,” CMS notes in its fact sheet. “Compression garments for treatment of lymphedema have not been previously covered by Medicare because, prior to the enactment of the CAA, 2023, there was no statutory benefit category for such items,” the agency explains.
• DMEPOS. Other durable medical equipment provisions codify the definition of a brace and revise and define the auto refill policy.