NOW AVAILABLE: The CMS CY 2025 Home Health Proposed Rule

by Elaine Gardner, MS, RN, COS-C, CPHQ, CHPN

On June 26, 2024, the Centers for Medicare & Medicaid Services (CMS) issued the Calendar Year (CY) 2025 Home Health Prospective Payment System (HH PPS) Rate Update proposed rule. This proposed rule updates HHA Medicare payment rates, Home Health Quality Reporting Program (HHQRP) requirements, Home Health Value-based Purchasing (HHVBP) Model requirements, and other Medicare policies.

Proposed changes and updates for HHQRP and the HHVBP Model

HHQRP

CMS is proposing, beginning with the CY 2027 HH QRP, to add four new OASIS assessment items as standardized patient assessment data elements in the social determinants of health (SDOH) category:

• One Living Situation item which provides response options to the question: “What is your living situation today?”
• Two Food items which provide 5 response options for the statements:
  – “Within the past 12 months, you worried that your food would run out before you got money to buy more”
  – “Within the past 12 months, the food you bought just didn’t last and you didn’t have money to get more.”
• One Utilities item which asks: “In the past 12 months, has the electric, gas, oil, or water company threatened to shut off services in your home?”

CMS is also proposing to modify one OASIS assessment item collected as a standardized patient assessment data element in the SDOH category:

• The current Transportation item, A1250, to align it with a Transportation item collected in other CMS programs, and ask: “In the past 12 months, has lack of reliable transportation kept you from medical appointments, meetings, work or from getting things needed for daily living?”

Social determinants of health are the socioeconomic, cultural, and environmental circumstances in which individuals live that impact their health. Adding access to standardized data relating to SDOH on a national level permits CMS to conduct periodic analyses, and to assess their appropriateness as risk adjustors or in future quality measures.

Additionally, CMS is proposing an update to the end of the suspension of OASIS all-payer data collection, and to change all-payer data collection to begin with the Start of Care (SOC) OASIS timepoint instead of the Discharge OASIS timepoint.

The SOC is the first assessment that can be submitted for a non-Medicare/non-Medicaid patient:

• On or after January 1, 2025 for the phase-in (voluntary) period
• On or after July 1, 2025 for the mandatory period

CMS will use the M0090 Date Assessment Completed date of the SOC assessment to identify non-Medicare/non-Medicaid patient assessments in the phase-in and mandatory periods.

Lastly, CMS is seeking information on future HH QRP quality measure (QM) concepts. Currently the HHQRP includes 21 measures for the CY 2024 program year, and CMS is inviting public comment on 4 measure concepts to inform future measure development efforts:

• Composite of vaccinations
• Depression
• Pain management
• Substance use disorders

HHVBP Model

The purpose of these updates is to obtain feedback on potential new performance measures and measure concepts for potential future rulemaking. The updates are as follows:

1. CMS is including a request for information (RFI) related to future measure concepts for the Model. CMS specifically requests public comments on several specific performance measures as well as general comments on other future model concepts that may be considered for inclusion in the expanded HHVBP Model.These include a combination of new measure concepts (for example, family caregiver measure), already developed measures that are not currently in the measure set for the expanded HHVBP Model (for example, Medicare Spending per Beneficiary (MSPB)), and new OASIS-based and claims-based measures.
2. CMS is considering integrating health equity in the Expanded HHVBP Model, and is providing an update to the RFI, Future Approaches to Health Equity in the Expanded HHVBP Model, that was published in the CY 2023 HH PPS final rule (87 FR 66874, November 4, 2022) and subsequently updated in the CY 2024 HH PPS final rule (88 FR 77687, November 13, 2023).
3. CMS is exploring potential definitions to use for defining historically underserved communities, and the use of potential social risk factors that can serve as a proxy to identify the underserved.
4. CMS is providing a reminder, as stated in the CY 2024 HH PPS final rule (88 FR 77790), that they will gather at least 2 years of performance data, and study effects of the expanded Model on health equity outcomes before incorporating any potential changes to the expanded Model regarding health equity.

Comment period

CMS will accept comments on the proposed rule through August 26, 2024, no later than 5pm EDT. In commenting, refer to file code CMS-1803-P. Comments may be submitted via any one of the following ways:

1. Electronically to https://www.regulations.gov
2. Regular mail:
   Centers for Medicare & Medicaid Services
   Department of Health and Human Services
   Attention: CMS-1803-P
   P.O. Box 8013
   Baltimore, MD 21244-8013
3. Express or overnight mail:
   Centers for Medicare & Medicaid Services
   Department of Health and Human Services
   Attention: CMS-1803-P
   Mail Stop C4-26-05
   7500 Security Boulevard
   Baltimore, MD 21244-1850

The document is currently available online and is scheduled to be published in the Federal Register on 07/03/2024.

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