Home Health & Hospice Week

Plus: Burdensome SPADE implementation, a maintenance therapy change, and more are on deck in final rule.

While reimbursement-related changes in the 2020 home health final rule are getting the lion’s share of attention, a number of other topics should land on your priority list too.

Take a look at these provisions from the final rule:

• OASIS for all. HHAs ridiculed the idea of collecting OASIS on all patients, not just Medicare ones, in their comment letters on the proposed rule. But that doesn’t seem to have deterred the Centers for Medicare & Medicaid Services on the topic. “We appreciate all of the feedback that we received on this issue and we will take it into consideration in our future policy and propose it in future rulemaking whereby HHAs would be required to collect and submit data on HH patients regardless of their payer,” the final rule says.
• SPADEs. Many commenters expressed reservations about certain of the 22 standardized patient assessment data element items or their many sub-elements, as well as the burden associated with implementing them (see Eli’s HCW, Vol. XXVIII, No. 37). But in the final rule CMS says “a majority of commenters expressed support for the adoption of the SPADEs within the categories of: cognitive function and mental status; special services, treatments, and interventions; medical condition and comorbidity data; and impairments.”

In its fact sheet on the rule, CMS notes that it “is finalizing the adoption of a number of SPADEs to fulfill IMPACT Act requirements, including “social determinants of health (race and ethnicity, preferred language and interpreter services, health literacy, transportation, and social isolation).” The additions to OASIS “will improve coordination of care and facilitate communication between HHAs and other members of the healthcare community, which is in alignment with CMS’s strategic initiative to improve interoperability,” the fact sheet says.

• Therapy assistants. CMS “is modifying current regulations to allow therapist assistants to perform maintenance therapy under the Medicare home health benefit in accordance with individual state practice requirements,” the agency says in the sheet.
• HHQRP. CMS has finalized two new quality measures that assess the transfer of health information and an update to the specifications for the Discharge to Community Post-Acute Care measure to exclude baseline nursing home residents. CMS also has finalized the removal of the Improvement in Pain Interfering with Activity Measure (NQF #0177), although it does not remove a related CAHPS survey question on pain as proposed.
• Home infusion. CMS is finalizing the provisions to create a permanent home infusion benefit, although experts agree the policy falls far short of what’s needed. Medicare “will group home infusion drugs into three payment categories, each with a unit of single payment, paid at amounts in accordance with specified infusion codes and units for such codes under the Physician Fee Schedule (PFS),” the fact sheet explains. Advocates have called on Medicare to adopt a daily per diem instead. CMS is also “soliciting comments in this final rule with comment period on ways to enhance coverage of eligible drugs under the home infusion benefit,” it says in the sheet.
• HHVBP. “For CY 2020, we are finalizing our proposal to publicly report the Total Performance Scores (TPS) and TPS Percentile Ranking from the Performance Year 5 (CY 2020) Annual TPS and Payment Adjustment Report (Annual Report) for each Home Health Agency (HHA) in the nine Model states that qualified for a payment adjustment for CY 2020,” CMS says in the fact sheet. “We expect that these data would be made public after December 1, 2021.”