On June 28th, 2021 the Centers for Medicare & Medicaid Services (CMS) issued a notice of proposed rulemaking [CMS-1747-P] proposing routine updates to the home health and home infusion services payment rates for calendar year (CY) 2022 and changes to the Home Health Quality Reporting Program (HHQRP). CMS is also proposing to expand the Home Health Value Based Purchasing Program (HHVBP) nationally.
Home Health Value-Based Purchasing Expansion
CMS is proposing to expand the Home Health Value-Based Purchasing (HHVBP) Model from the original 9 states, to include all 50 states, territories, and District of Columbia beginning January 1st, 2022. It is also proposed that the original HHVBP Model end one year early for the agencies in the nine original Model States, such that CY 2020 performance data would not be used, and no payment adjustment would be made in CY 2022 as described under the original Model. As proposed, agencies will compete nationally within one of two size-based cohorts for a proposed payment increase or reduction of up to 5 percent.
Home Health Quality Reporting Program Updates and OASIS-E Implementation
CMS is also proposing multiple changes to the Home Health Quality Reporting Program (HH QRP). CMS is proposing to implement OASIS-E effective January 1st, 2023. The OASIS-E instrument includes certain Standardized Patient Assessment Data Elements including those which will allow the reporting of two new measures: Transfer of Health Information to Provider and Transfer of Health Information to Patient. CMS also proposes to retire the OASIS-based measure, Drug Education on All Medications Provided to Patient/Caregiver, and remove from the OASIS, item M2016 – Patient/Caregiver Drug Education Intervention on which the Drug Education measure is based. The rule also proposes to retire two claims-based measures, (Acute Care Hospitalization During the First 60 Days of Home Health and Emergency Department Use without Hospitalization During the First 60 Days of Home Health) and replace them with the Home Health Within Stay Potentially Preventable Hospitalization (PPH) measure.
Two existing measures (Percent of Residents Experiencing One or More Major Falls with Injury and Application of Percent of Patients with an Admissions and Discharge Functional Assessment and a Care Plan that Addresses Function) are being proposed to be publicly reported beginning in April 2022, after a COVID/PHE-related delay.
OT Completion of Initial and SOC Comprehensive Assessment
CMS will modify regulatory language to allow an OT to complete the initial assessment and SOC comprehensive assessment for Medicare patients when OT is ordered with SLP and/or PT but where skilled nursing is not initially part of the plan of care. This does not reflect a change in the statutory requirements for establishing Medicare program eligibility. Only the need for skilled nursing, PT and/or SLP services continue to establish eligibility for the Medicare home health benefit.
The proposed rule also provides monitoring and analysis of the Patient-Driven Groupings Model (PDGM) and proposes to recalibrate the PDGM case mix weights, functional levels, and comorbidity adjustment comorbidity adjustment subgroups while maintaining the current low utilization payment adjustment (LUPA) thresholds for CY 2022.
The Proposed Rule can be accessed at: https://public-inspection.federalregister.gov/2021-13763.pdf
Public comments are invited and must be received by August 27, 2021.
Join the OASIS Answers Team at an upcoming Blueprint for OASIS Accuracy workshop to improve your agency’s data collection skills as you prepare for HHVBP, Quality Measure, and OASIS-E changes.