CMS releases CY 2025 home health PPS proposed rule, continues with budget neutrality adjustments

The Centers for Medicare & Medicaid Services June 26 issued its calendar year 2025 proposed rule for the home health prospective payment system, which would reduce net home health payments by an estimated $280 million, or -1.7%, in calendar year 2025 relative to the current year. This update includes a 3.0% market basket update, reduced by a 0.5% productivity adjustment. However, CMS is also proposing to reduce the base payment rate by 4.1% due to the implementation of the Patient-driven Groupings Model, which reduce total payments by 3.6%. The AHA has raised serious concerns about such adjustments, which come on top of multiple years of similar downward adjustments. CMS also is proposing to adjust the fixed-dollar loss amount for high-cost outliers, which it estimates will reduce payments by an additional 0.6%, or $100 million.

CMS also proposes to update the HHA Conditions of Participation to add a new standard that would require HHAs to develop, consistently apply, and maintain a policy for accepting patients to service. While CMS does not propose to adopt or remove any quality measures from the HH Quality Reporting Program, the agency proposes to adopt and modify certain patient assessment items related to health-related social needs; HHAs would be required to collect and report specific data elements related to living situation, food and utilities beginning with the CY 2027 HH QRP. The agency would also remove an element found to be redundant. As finalized in previous rulemaking, CMS will end the suspension of all-payer data collection also beginning with CY 2027 and proposes practices for this requirement. 
Finally, CMS proposes to revise the infection prevention and control requirements for long-term care facilities to extend reporting to the Centers for Disease Control and Prevention of a subset of the current COVID-19 data elements and also require reporting for data related to influenza and RSV to begin Jan. 1, 2025.

CMS will accept comments on the proposed rule through Aug. 26. AHA members will receive a Special Bulletin with additional details on the rule in the coming days.