At a Glance
November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) issued a final rule to update the home health (HH) prospective payment system (PPS) for calendar year (CY) 2022.
We appreciate CMS’ issuance of a streamlined rule, which allows HH agencies, as well as their hospital and other local partners, to focus on their response to the COVID-19 pandemic. While virus surges continue in many communities, in others, HH agencies are now caring for the clinical needs of “long-haul COVID-19” and other patients while preparing for a possible resurgence of the virus during the fall and winter seasons.
In addition, AHA supports CMS’ caution in determining how best to ensure that the new HH PPS case-mix system was implemented in a budget-neutral manner in CY 2020, especially given the complexities wrought by the pandemic. That said, we remain concerned about the prospective nature of the CY 2020 behavioral adjustment, especially given that analyses conducted thus far indicate a substantial gap between CMS’ and independent findings. Specifically, CMS found that Medicare overpaid for HH services in CY 2020, while analyses by HH stakeholders found an underpayment for that year. Moving forward, we urge CMS to partner with stakeholders to transparently evaluate projected annual payments versus actual payments that year. In addition, we appreciate that CMS will delay the expansion of the HH Value-based Purchasing model for one year as we suggested, but continue to be concerned by other details in the model’s design.
Watch for a detailed Regulatory Advisory in the coming weeks. In addition, AHA’s HH members will receive a separate invitation to a member call to discuss the rule and its impact.
The final rule:
- Increases net payments by 3.2% ($570 million).
- Does not alter the behavior offset amount implemented in CY 2020.
- As required by law, allows occupational therapists to conduct initial and comprehensive patient assessments.
- Finalizes certain COVID-19 public health waivers related to the virtual supervision of HH aides.
- Delays for one year the nationwide expansion of the HH Value-based Purchasing pilot.
- Removes three and adds one new quality measure.