President Donald Trump recently signed a federal spending bill into law that includes many measures that will impact the home health care industry. Home Health agencies are advised to become familiar with these developments and stay informed on the latest regulatory guidelines that impact agency processes and practices. While care in the home continues to grow, federal regulators continue to make changes that require agencies to operate with ever-greater attention to all aspects of operations in seeking to achieve the best possible outcomes for patients and clients. Below are some of the key measures in the new law impacting home health.
Payment reform
The new law includes plans to reform home health payments in 2020. It includes the reintroduction of 30-day payment periods from the Home Health Grouper Model (HHGM). Changing from 60-day payment episodes to 30-day payment periods will mean that agencies will need to bill twice in every 60-day care episode. This will more closely align home health payment periods with other healthcare settings, which already bill in 30-day or monthly periods. It remains to be seen if home health will eventually go to calendar month billing versus simply 30 days of variable 60-day episodes.
The HHGM, as introduced to our industry in a proposed HHPPS rule July 2017, included several grouper model changes. These revisions rely on a more heavily weighted clinical picture of the patient, and less on therapy visit thresholds from episode payment groupers. It also changes the early episode to the first 30-day period only, using referral source type as a grouper factor, in addition to placing the patient’s primary diagnosis into one of six clinical groupers, retaining functional status as a factor, and adding a possible comorbidity adjustment for certain selected chronic illness diagnoses. The HHGM, as proposed last year, did not require these sweeping changes to be implemented in a budget-neutral manner, which would have led to deep cuts in home health payments. However, the new law states that implementation of the HHGM must be done so in a budget neutral manner.
CMS will continue to gather information from stakeholders in the coming months (including holding at least one session of a technical expert panel) before making final decisions on what the final iteration of the reformed payment system will look like.
Medicare eligibility documents
There is encouraging news for agencies undergoing challenges with Face to Face and Certification documentation. Currently, the home health agency’s clinical documentation is not considered when the Medicare Administrative Contractor (MAC) reviews documentation for medical necessity. Instead, only the clinical encounter notes from the provider who saw the patient, and some agency documentation (which must subsequently be reviewed, signed, and made part of the provider’s clinical documentation) are considered. The recent law gives the MACs the authority and instruction to consider documentation from the agency as part of their determination as to whether the patient meets Medicare beneficiary home health coverage criteria. This will greatly reduce the burden of proof for both home health agencies, as well as medical providers.
Rural add-on
The rural add-on, which gives additional funding so that agencies can service patients in distant areas, was approved for continuation at current levels for 2018. Starting in
2019, the home health add-on will increase from three to four percent for counties with a population density of six or fewer individuals per square mile. The add-on will be phased down through 2022: three percent in 2020, two percent in 2021 and one percent in 2022.
Market basket updates
The new law increased the market basket rate for home health from 1.4 percent to 1.5 percent for the year 2020. This will result in a cut of about $3.5 billion dollars for agencies, which is more than agencies have faced in the past six years.
As always, one of the only consistencies in home health is change. Our industry is ever-evolving and ever-growing. At Axxess, we are committed to change, evolve and grow with our clients and others in the industry. Be sure to check out our resources and offerings pages for more information on our suite of solutions.
