Proposed CY 2022 Home Health PPS Rule Would Extend Value-Based Purchasing Model and Seeks to Collect Health Equity Data Through Quality Reporting Program | Baker Ober Health Law


On July 7, 2021, the Centers for Medicare & Medicaid Services (CMS) released their proposed rule to update the Home Health Prospective Payment System (HH PPS) and Value-Based Purchasing (HH VBP) of calendar year (CY) 2022. In the proposed rule, CMS notes that its experience with the home health value-based purchasing model has been successful enough to justify adopting the model at home. nationwide earlier than expected. The agency also seeks to collect information to guide its efforts in collecting health equity data that can influence policy development. The proposed rule impacts aspects of home health, palliative care, long term care hospitals and inpatient rehabilitation care, reimbursement, data collection and reporting. CMS is accepting comments on the proposed rule until August 27, 2021.

Early expansion of the home health value-based purchasing model

CMS seeks to capitalize on the success of the CMS Innovation Center HH VBP model by proposing to terminate the model in the original model states one year earlier and expand the model nationwide effective January 1, 2022 The model is designed to encourage improvement in the quality of care. for seniors and people with disabilities who depend on Medicare for home care, without negating or limiting coverage or benefits for Medicare beneficiaries. In its latest assessment, participants in the home health agency model showed an average 4.6% improvement in their quality scores and an average annual savings of $ 141 million for the Medicare program.

Payment updates and policy changes

CMS is offering the following payment updates and policy changes for home health agencies and home infusion therapy providers for CY 2022:

  • Patient-Centered Cluster Model (PDGM)

    In January 2020, Medicare implemented the PDGM and a 30-day payment unit to better align the Prospective Home Health Payment System (HH PPS) with patient care needs and ensure that clinically complex beneficiaries have sufficient access to home health care. In implementing these changes, CMS finalized three behavioral assumptions regarding the coding of clinical groups, coding for co-morbidities and a low usage payment amount (LUPA) that resulted in a reduction in the national standardized payment rate on 30 days CY 2020.

    In the proposed rule, CMS is seeking feedback on the method it describes for fulfilling its statutory responsibility to determine the impact of the differences between the supposed behavior changes and the actual behavior changes, and to adjust the amount. 30-day payment accordingly. At the same time, CMS also offers:

    • recalibrate case weights, functional levels and comorbidity adjustments associated with PDGM using more recent data from CY 2020 to increase the accuracy of payments for the types of patients served by home health agencies;
    • maintain the LUPA CY 2021 thresholds for CY 2022;
    • conform the wording of the regulation to allow the implementation of a new legal provision under which occupational therapists can perform initial and comprehensive assessments for all Medicare beneficiaries through Home Health, provided the plan care does not initially include skilled nursing care, but includes physiotherapy or speech therapy; and
    • using a LUPA physiotherapy complementary factor as an indicator of the average excess minutes for the first LUPA periods where the initial and full visits are made by occupational therapists until a more precise complementary factor can be established at the CY 2022 data help.
  • Benefits of Home Infusion Therapy for CY 2022

    CMS proposes to complete a separate statutory mandate updating the payment rates for home infusion therapy services for the year 2022. The agency also recommends updating the geographic adjustment factor used for the adjustment salaries, but maintaining the initial and subsequent visit payment policy finalized in the PPS CY 2020 HH. final rule with comment period. Overall, CMS expects the economic impact of the updated payment rates for home infusion therapy to be minimal.

Home Health Service Quality Reporting Program Proposals

CMS is making several proposals regarding the Home Health Quality Reporting Program (HH QRP), including proposed policies to advance health equity, in accordance with President Biden’s recent Executive Order 13985. The proposed rule includes two requests for information (RFI). The first RFI invites comments on methods of achieving health equity through policy. The agency plans to improve data collection to better measure and analyze disparities between its programs and policies in order to address large and persistent health inequalities among Americans. The second RFI invites comments regarding CMS’s future plans to define digital quality metrics for the HH QRP and on the potential use of rapid healthcare interoperability resources.

In addition, CMS makes several proposals regarding the operation of the HH QRP, including:

  • improve the home care quality reporting program by removing or replacing certain quality measures;
  • the introduction of a claims-based metric that addresses concerns about attribution with a metric more strongly associated with desired patient outcomes; and
  • start collecting data on the measure Health Information Transfer to Provider – Post Acute Care and six categories of standardized patient assessment data elements to better support care coordination:
    • home health agencies would start collecting data from January 1, 2023, and
    • long-term care hospitals and inpatient rehabilitation facilities would begin collecting data as of October 1, 2022.

Home Health Conditions of participation

The agency proposes to allow home helpers to use interactive telecommunications systems during the 14-day supervisory assessment only for unforeseen events that would otherwise interrupt scheduled on-site and in-person visits.

Investigation and Enforcement Requirements for Hospice Palliative Care Programs

CMS proposes to improve the palliative care program investigation process by changing the composition of investigation teams, creating new enforcement mechanisms and authorities, and increasing the role of accrediting organizations (AOs). Concretely, CMS offers:

  • require the use of multidisciplinary investigative teams;
  • prohibit conflicts of interest for surveyors;
  • establish a hotline for complaints about the palliative care program;
  • the creation of a special program for underperforming palliative care programs;
  • empower CMS to impose new enforcement measures on non-compliant hospice palliative care programs in order to encourage underperforming hospice programs to substantially comply with CMS requirements before CMS has to terminate it ‘palliative care provider agreement; and
  • for AOs who accredit and “judge” hospice palliative care programs, such as the Health Care Accreditation Commission, Community Health Accreditation Partner, and Joint Commission:
    • extend CMS-based surveyor training to AOs
    • require AOs with CMS approved palliative care programs to begin using form CMS-2567.

Interested stakeholders should submit their comments either electronically through, or by regular, express, or overnight mail directly to CMS for receipt by 5:00 p.m. ET on August 27, 2021.

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