CMS Releases Proposed Rule for FY2015 Home Health Payment System
Tuesday, July 8, 2014
by: Visiting Nurse Associations of America

Section: Public Policy and Advocacy

Last week the Centers for Medicare and Medicaid Services (CMS) released a proposed rule for the FY 2015 Home Health Prospective Payment System (HHPPS). The proposed rule would have a net reduction to home health payments by 0.3 percent about $58 million in 2015. The proposed net cut reflects the effects of the 2.2 percent increase to home health payment update percentage ($427 million increase) along with decreases in national rebasing adjustments, per-visit payment rates, and the non-routine medical supplies (NRS) conversion factor.

Importantly, the rule includes a major proposed change to the face-to-face requirement. The Affordable Care Act mandates that a Medicare beneficiary must have a face-to-face encounter with a physician to certify that the patient is homebound and in need of skilled care. CMS also required that the physicians provide a thorough narrative explaining the patient's circumstances. This narrative requirement faced growing opposition from the provider community, including VNAA, which claimed that the burdensome requirement and subsequent denials was impeding vulnerable patients from getting care they need.

The FY2015 rule proposes to eliminate the written "narrative" that physicians are currently required to provide as part of the face-to-face encounter. Physicians will still be required to perform the face-to-face certification and will have to document that the encounter took place. In addition, CMS proposes that patients' medical records from their certifying physician or discharging facility will be sufficient in determining initial eligibility for the Medicare home health benefit. However, if the beneficiary is deemed ineligible to receive home health benefit, the physician visit to determine eligibility would be a non-covered service.

In addition, CMS is inviting comment from stakeholders on a value-based purchasing (VBP) model for home health agencies (HHAs) in certain states that it is considering testing, to begin in CY 2016, where payments would be tied to the quality of care that HHAs provide.

To view fact sheets, summaries, and the full rule, please click here.

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