On June 17th, 2022 the Centers of Medicare & Medicaid Services (CMS) posted a notice of proposed rule making [CMS-1766-P]. In addition to proposing routine updates to the home health and home infusion services payment rates for calendar year CY 2023, of note were proposed changes to the Home Health Value-Based Purchasing baseline years and changes to the Home Health Quality Reporting Program (HHQRP). CMS is soliciting public comments on publicly reporting a composite structural health equity quality measure; displaying descriptive information on Care Compare from the data HHAs provide to support health equity measures; and the impact of the domains and quality measure concepts on organizational culture change. The proposed rule also solicits for comments on collection of telehealth data on home health claims.
Home Health Quality Reporting Program Updates – Expand OASIS data collection to all payers
CMS is proposing to end the suspension of collection of OASIS for non-Medicare/non-Medicaid HHA patients. This would expand the requirement to collect and submit OASIS data for all payers beginning with CY 2025.
Home Health Value Based Purchasing Model – New Definitions!
CMS is proposing to clarify the term baseline year with the terms HHA baseline year and Model baseline year and to change the calendar years associated with each of those baseline years. The HHA baseline year is proposed to be defined as the calendar year used to determine the improvement threshold for each measure for each individual competing HHA. The Model baseline year would be defined as the calendar year used to determine the benchmark and achievement threshold for each measure for all competing HHAs. The rule also proposes to change the Model baseline year from CY 2019 to CY 2022, and for home health agencies that obtained Medicare certification prior to January 1, 2022, the rule also proposes to change the HHA baseline year to CY 2022 for all applicable measures.
Use of Telecommunications Technology under the Home Health Benefit
CMS is proposing to collect data on the use of services furnished using telecommunications technology as defined in the CY 2021 HH PPS final rule. This would allow CMS to analyze the characteristics of the beneficiaries that are utilizing services furnished remotely.
The proposed rule proposes to recalibrate the PDGM case mix weights, including functional levels and comorbidity adjustment subgroups and LUPA thresholds using CY 2021 data.
Public Comment Opportunity
OAI encourages all home health agencies and interested stakeholders to read this proposed rule and provide CMS with your feedback, especially on topics where you have questions, concerns, or recommendations.
The proposed rule can be accessed at https://public-inspection.federalregister.gov/2022-13376.pdf.
Public Comments must be received no later than 5:00 pm on August 16, 2022.