2019 Final Rule, More Changes and our Analysis

Last time, we discussed the biggest changes in the CMS’ Final Rule for 2019.  Now, let’s take a closer look at changes to reporting, regulatory reduction, and what this means for you.

Quality Reporting Program

As quality care becomes a major player in reimbursement and volume is no longer a factor, the ability to track certain metrics has become cumbersome. To address this, CMS is going to be removing seven quality measures. Those measures are removed based on eight removal factors. This component of change is still being worked on and more information will be released in the coming year.

Value-Based Purchasing Model (HHVBP)

As the push for quality reporting becomes a permanent feature, the HHVBP model will see two measures tied to the OASIS removed. The measures asking if a flu shot was received and if the flu shot was ever received will be no longer be reported.

Instead, two new measures will be reported. The composite measures will be based on mobility and self-care.  These new measures will change the calculation methodology for public reporting and ultimately reduce how quickly agencies can show improvement on Home Health Compare and HHCAHPS measures.

Regulatory Burden Reduction

As discussed in the proposed rule, and part of the Trump Administration’s goal to reduce regulatory burdens across government, home health gets a little relief. CMS will no longer require physicians to estimate the length of services that will be needed by the patient upon recertification.

CMS’ estimated reduced cost to physicians of $14.2 million. As for agencies, the savings is to be determined. However, charts will no longer be denied for having incomplete documentation if a physician doesn’t include the estimated length of services required as part of the recertification.


Agencies have some positive news for once! The increase in reimbursement is not only a positive step forward in terms of recognizing the benefits of home health, but it also is a step forward in helping agencies financially recover.  As agencies get a sign of relief for 2019, the trojan horse lies in the new reimbursement model, PDGM, in 2020.

2020 is going to be the major year when agencies are forced to sink or swim.  Our hope is that agencies begin preparing early, fine tuning and being ready for January 1, 2020.  The new PDGM system is going to be a massive change to reimbursement and the first few OASIS and admissions that are completed might be a little tough.  As we work our way through 2019, Home Health Today is going to be focusing on tips, tools, and educational material to really help agencies like your sort out the important aspects and priorities.

Next year’s 2.2% increase is not only warranted but needed. Financially, home health agencies need the additional infusion of cash to survive and prosper, but also to prepare for PDGM. While the additional cash flow and profit is helpful, this new wiggle room must be used wisely.  A budget and a plan on how to use the new cash will be a good start to preparing for the future.

2019 would be a good year for agencies to develop new policies, procedures and get their houses in order – financially and operationally. As we’ve been focusing on operations over the past few months, now is the time to put those plans in motion and solidify your agency’s plan for 2019, 2020 and even 2021.  Forward-looking agencies will start now, slower agencies will wait until 2019 is already in motion and those that wait until 2020, will be left behind.

Do you have questions, do you need answers or guidance? Now is the time to reach out to us. As we get closer to the end of the year, being prepared will not only be a solution, but a solid foundation for your agency to grow.