Home Health & Hospice Week

GG items, telehealth, and more round out the newly proposed home health rule.

Home health agencies’ hands are more than full with their current and prospective reimbursement and regulatory duties. But they shouldn’t let these important provisions from the 2023 home health proposed payment rule falls through the cracks:

• GG items. The IMPACT Act “requires that HHAs report standardized patient assessment data” and the Centers for Medicare & Medicaid Services accordingly implemented GG items on the OASIS tool. But “the GG functional items are not currently used to determine the functional impairment level under the [Patient-Driven Groupings Model],” notes the rule released June 17. “CMS continues to use the M1800-1860 items to determine functional impairment level for case-mix purposes.”

CMS conducted an “analysis … to explore the relationship between the M1800–1860 items used in the PDGM and the analogous GG items,” the rule notes. “There is a correlation between the current responses to the M1800–1860 items and the GG items,” CMS found. But GG items not being required at follow-up and a “significant amount” of activity not attempted (ANA) responses make drawing conclusions difficult.

HHAs shouldn’t dismiss “the analysis going on with the GG items and how those items correspond with the M1800-1860 items,” urges consultant Angela Huff with FORVIS, the new firm formed by the merger of BKD and DHG. “CMS is signaling the significance of these items and the role they could play in PDGM in the future. GG items should not be overlooked,” Huff stresses.

• Telehealth claims reporting. “Data on the use of telecommunications technology during a 30-day period of care at the beneficiary level is not currently collected on the home health claim,” CMS observes in the rule published in the June 23 Federal Register.

CMS aims to begin collecting data on the use of telecommunications technology by Jan. 1, 2023, on a voluntary basis by HHAs, then a mandatory basis by July 2023. “Specifically, we are soliciting comments on the use of three new G-codes identifying when home health services are furnished using synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system; synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system; and the collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency, that is, remote patient monitoring,” according to the rule.

“Collecting data on the use of telecommunications technology on home health claims would allow CMS to analyze the characteristics of the beneficiaries utilizing services furnished remotely, and could give us a broader understanding of the social determinants that affect who benefits most from these services, including what barriers may potentially exist for certain subsets of beneficiaries,” the agency says in its fact sheet about the rule.

• Health equity. “CMS is seeking stakeholder feedback on our work around health equity measure development for the Home Health QRP and the potential future application of health equity in the Expanded HHVBP Model’s scoring and payment methodologies,” the agency says in the fact sheet.
• Home Infusion Therapy (HIT). CMS doesn’t have the data needed to update the HIT payment rates yet, it notes in the rule. That data will be in the physical fee schedule rule for 2023. “The updated … national home infusion therapy payment rates, and locality-adjusted home infusion therapy payment rates will be posted on CMS’ Home Infusion Therapy Services webpage once these rates are finalized,” the rule notes.

“In the future, we will no longer include a section in the HH PPS rule on home infusion therapy if no changes are being proposed to the payment methodology,” CMS adds. “Instead, the rates will be updated each year in a Change Request and posted on the website.”