In The News

Beyond The Cuts: What Else Home Health Providers Need To Know About CMS’ 2024 Final Rule

Home Health Care News / By Patrick Filbin
Nearly a month after the U.S. Centers for Medicare & Medicaid Services (CMS) released its CY 2024 final payment rule, the ins and outs of it have become more apparent. And there’s more to delve into than just blanket rate cuts.
Aside from the headline-grabbing 0.8% aggregate payment increase and the permanent prospective adjustment of -2.890%, there are dozens of other notable changes to home health care that providers should be aware of.
HHVBP program
More changes to the Home Health Value-Based Purchasing (HHVBP) model are in order.
More specifically, CMS is attempting to simplify performance scores.
“They’ve replaced the two normalized composite measures around self-care and mobility with a discharge function score,” Joseph Brence, head of clinical strategy for MedBridge, told Home Health Care News. “Additionally, the discharge community measure has been replaced with the discharge to community post-acute measure. These changes should make it easier for agencies to understand their performance without waiting for internal performance reports.”
Another positive change in value-based purchasing Brence laid out is replacing the acute care hospitalization measure – during the first 60 days of home health use – with the potentially preventable hospitalization measure.
By shifting to the latter, CMS is instead putting the focus on hospitalizations and ED usage that a home health agency would have been able to avoid. Today, an agency would be penalized every time a patient goes to the emergency room or is admitted to the hospital.
This change is narrowing the focus to what home health agencies can actually prevent, Brence said.
“That is a win for home health agencies,” Brence said. “So the attention and changes to how value-based purchasing is assessed does benefit the home health setting.”
Wage index, labor portion updates
From a revenue perspective, agencies can’t take the 0.8% increase at face value. One of the major updates every year in the final rule is the wage index value updates.
The wage index determines Medicare payments for home health services and is part of the calculation used by CMS to adjust payments based on regional variations in labor costs.
The wage index reflects the relative wage levels in the area where a home health agency is located.
There are over 450 Core-Based Statistical Area (CBSA) codes that get updated every year.
A majority of those codes — 59% — had a negative change in the final rule. Of those, 22.7% had a negative impact of over 3%.
“If you’re looking at agencies that are thinking, ‘Alright, we’re at least going to have a higher rate for next year, so we should be in the black when we do an apples-to-apples comparison,’” Nick Seabrook, managing principal and SVP of consulting at SimiTree, told HHCN. “Well, that might not necessarily be the case, based on the fact that the wage index values are going down.”
On the flip side, there were 38% that had a positive change — 10.8% had a change of 3% or higher…

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NHPCO Collecting Signatures for Rural Letter to Congress

NHPCO is collecting organizational signatures from rural and frontier providers for a letter to Congress. This letter is intended to highlight the issues rural and frontier providers are facing and to begin partnership with Congress on these issues. Review the letter and sign on by Friday, December 8.

If you are interested in getting more involved with rural provider issues, volunteer to be a member of the rural community steering committee. All disciplines are welcome as well as individuals who have not participated in NHPCO leadership roles previously. Email Alix Ware at [email protected] with a short introduction.


Report: Waiting Lists Preventing Hundreds of Thousands from Accessing HCBS

McKnight’s Home Care / By Adam Healy

Since 2016, waiting lists for home- and community-based services (HCBS) have kept more than 600,000 people from accessing care each year, while staffing woes and funding uncertainties present no hope for improvement, a new report finds. 
More than 70% of these people waiting in line have intellectual or developmental disabilities, while another 25% are adults and seniors with physical disabilities, according to a recent report from KFF. In 2023, there were a total of 692,000 people waiting to receive HCBS, and the number has steadily gone up in each of the last three years.
“Waiting lists may reflect both shortages of workers and insufficient state funds,” KFF noted. “Although states reported increasing provider payment rates and other efforts to bolster the workforce, challenges remain and some of states’ policies for addressing those challenges have ended with the conclusion of pandemic-era programs.” 
Long-term services and supports, which include HCBS, are historically grossly underfunded, and states will likely have to chip in more next year as enhanced federal funding brought on by the COVID-19 pandemic expires. But though the workforce shortage often keeps Medicaid beneficiaries stuck waiting, state processes can also create obstacles, according to the report. 

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CMS Accepting Applications for GUIDE

The Health Group 

CMS is now accepting applications for the Guiding an Improved Dementia Experience (“GUIDE”) Model.  The GUIDE Model will focus on dementia care management and aims to improve quality of life for people living with dementia, reduce strain on their unpaid caregivers, and enable people living with dementia to remain in their home and communities.  The program is intended to provide a comprehensive package of care coordination and management, caregiver education and support, and respite services.

Through the GUIDE Model, CMS will test an alternative payment for participants that deliver key supportive services to people with dementia, including comprehensive, person-centered assessments and care plans, care coordination, and 24/7 access to a support line. Under the model, participants will assign people with dementia and their caregivers to a care navigator who will help them access services and supports, including clinical services and non-clinical services such as meals and transportation through community-based organizations. 

Additional details are available here and here.


Fact Sheet: Nondiscrimination on the Basis of Disability Proposed Rule Section 504 of the Rehabilitation Act of 1973

U.S. Department of Health and Human Services

The Department of Health and Human Services (HHS) has issued a proposed rule to advance equity and bolster protections for people with disabilities.  The proposed rule, Discrimination on the Basis of Disability in Health and Human Service Programs or Activities, updates, clarifies, and strengthens the implementing regulation for Section 504 of the Rehabilitation Act of 1973 (Section 504), the statute that prohibits discrimination against otherwise qualified individuals on the basis of disability in programs and activities that receive Federal financial assistance or are conducted by a Federal agency.

The historic proposed rule provides robust civil rights protections for people with disabilities in federally funded health and human services programs. It advances the promise of the Rehabilitation Act and helps to ensure that people with disabilities are not subjected to discrimination in any program or activity receiving funding from HHS just because they have a disability.  This proposed rulemaking is consistent with Section 504 statutory text, congressional intent, legal precedent, and the Biden-Harris Administration’s priority of advancing equity and civil rights and protecting Americans’ access to health care and human services programs and activities.  

Read the full Proposed Rule

[The first 50 pages are the rationale and students that support changes that are relevant to in-home providers; Pages 340-400 are the actual proposed rule]

Read a Summary of the Rule

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