Home Health & Hospice Week

Plus: Circle August on your VBP calendar.

Just because the OASIS-E instrument is staying the same in 2024, doesn’t mean you don’t have new OASIS practices to keep up with.

Why? The OASIS-E form is holding steady in the new year, confirmed the Centers for Medicare & Medicaid Services in a Nov. 29 Home Health Open Door Forum. But CMS has updated both the OASIS-E Guidance Manual and the OASIS Questions and Answers, with links to both at www.cms.gov/medicare/quality/home-health/home-health-qrp-spotlight-and-announcements.

The updates incorporate guidance from July of 2022 through October 2023 in the CMS quarterly OASIS Q&As, pointed out CMS’ Jermama Keys in the Zoom call.

For example: In the guidance for K0520B, Feeding Tube, CMS has added “If a feeding tube is in place but there are no scheduled or prn orders to provide nutrition and/or hydration via the feeding tube on the current care/treatment plan, do not code K0520B Feeding Tube.”

Other home health issues addressed in the forum include:

• 2024 Final Rule. CMS staff reviewed the provisions from the final rule for next year, which was released earlier this month (see HHHW by AAPC, Vol. XXXII, No. 39-40). That includes the hotly contested behavioral adjustment provision.

The 2.89 percent cut — half of the amount CMS assessed — is required by law to make sure the switch to the Patient-Driven Groupings Model is budget neutral, CMS’ Kelly Vontran told forum attendees. It contributes to home health agencies’ slim 0.8 percent payment increase for 2024.

Tip: “The 2024 home health rate update is not a complete overhaul, but it’s more than a routine yearly increase,” notes CPA Scott Manson with accounting and advisory services firm Marcum. “While 2024 rates [are] now known, 2025 is another issue. Conservative planning for 2025 may include an increase similar to 2024, with the assumption that the full behavioral adjustment is included,” Manson says in online rule analysis.

“Providers will want to start planning for 2024 now and update their budgets for the changes,” Manson advises.

CMS’ MLN Matters article about 2024 reimbursement is at www.cms.gov/files/document/mm13411-home-health-prospective-payment-system-cy-2024-update.pdf.

• VBP. The forum also included a review of the rule’s Home Health Value-Based Purchasing provisions. Don’t forget that public reporting of HHAs’ VBP stats will begin a year from now in December 2024, CMS’ Marcie O’Reilly pointed out.

And agencies will receive their first annual performance reports in August 2024, O’Reilly reminded. They will include the payment adjustment percentage your agency will have applied to each Medicare fee-for-service claim in calendar year 2025.

Watch for: The final version of October’s VBP Interim Performance Reports will be out next week, O’Reilly noted. They will contain corrected discharge to community data, she said in response to a query in the question-and-answer portion of the session.

• dNPWT. Medical necessity will be your only limitation when it comes to billing disposable negative pressure wound therapy devices under new rules going into effect on Jan. 1. The claims processing system contains no limit on the number of units home health agencies can bill with the new dNWPT code, CMS’ Wil Gehne explained to a caller in the Q&A session.

Details of the new billing procedure are at www.cms.gov/files/document/mm13244-separate-payment-disposable-negative-pressure-wound-therapy-devices-home-health-claims.pdf.

• RCD. There’s still no official answer on whether the newly expanded Review Choice Demonstration will stretch beyond its current May 2024 end date.

Reminder: RCD is starting in Oklahoma on Dec. 1.