The Home Health Final Rule for 2015 provided some relief for agencies in terms of compliance, but at the same time is a slap in the face on the reimbursement side. CMS would like to pat itself on the back for cutting $60 million from agencies in 2015. In 2013, CMS estimated that $18 billion was spent on 3.5 million home health recipients, which equates to an average of $5,143 spent on each patient who received home health.
Rebasing continues to haunt agencies. In 2015, an increase in the national base rate for episodes is put in place. The final rule episodic base rate is $2,961.38 – an increase of $92.01 from 2014’s base episodic rate. While this looks like a positive increase on the surface, the calculations behind HHRG’s have changed. The change in case mix weights and budget neutrality factors wipe out any gain. Lower case mix weights are producing the lower calculated episodic reimbursement rate. Some rural counties who saw an increase in reimbursement due to their location will also be losing money. About 100 counties that once qualified for the additional reimbursement will no longer be included.
Face to Face
Many of you will miss the eloquently written physician narratives that explain the need for home health. As of January 1, 2015 the physician narrative has been eliminated and will no longer be required. Also, CMS has clarified that a certification is any time a new start of care is performed rather than for initial episodes. The National Association for Home Care and Hospice was a large force in pushing CMS to make this regulatory change. NAHC is currently focusing on trying to get CMS to backdate this new rule to ease the burden faced by many agencies.
As of January 1st, it’s time to wave good bye to the 13th and 19th visit requirements. Instead of basing the reassessment on visit counts, a 30 day window is provided. At least once every 30 days a therapist (not a PTA or OTA) must perform a visit and functionally reassess. This change is a welcome improvement over the initial draft of the final rule released over the summer, which proposed a 14 day reassessment period.
CMS is asking for more data and if you don’t comply, expect another 2% payment reduction. As most agencies already OASIS admission and discharge data, this won’t be a problem. But those who don’t submit at least 70% of their OASIS data can expect to lose that 2% quickly. Over the next two years, the rate will increase 10%, maxing out at 90%.
CMS has expanded and modified the definition of a Speech Therapist. Under the new conditions, a Speech Therapist must have a master’s or doctorate and be licensed by the state in which he or she practices. An alternative qualifying method is to complete 350 supervised clinical practicum hours, have at least 9 months of experience and pass a national exam.
Value Based Purchasing
The idea of Value Based Purchasing has been thrown around for a few years. Well, expect this idea to become a reality in 2016. CMS is currently proposing to start the test with 5-8 states. Payment models are still hazy and more information will need to be released, with a public comment period, before the testing can take place.
The 2015 Final Rule has some positive and negative aspects. The negative impact on your bottom line is clearly present. However, the Face to Face narrative elimination is a positive step. We need to continue to urge and pressure CMS to make informed and wise changes that improve home health, not limit access or negatively impact home health agencies like yours.