Summary of CMS Open Door Forum for Hospice

NAHC Report

November 29, 2923, the Centers for Medicare & Medicaid Services (CMS) held the Home Health, Hospice, and DME Open Door Forum. Below are key updates that provided for hospice providers. (GO HERE to read the summary for home health providers.)

Hospice Quality Reporting Program (HQRP)

The November 2023 quarterly refresh for the HQRP is now available on Care Compare. Additionally, the HQRP Quarterly Q&A for Q3 2023 is now available.

CMS announced the addition of a new webpage for hospice providers on how to verify and update their demographic information to ensure accuracy.

On November 14, 2023 CMS hosted a webinar that shared hospice-related updates around the Calendar Year (CY) 2024 Medicare Home Health Prospective Payment System (HH PS) Final Rule. Topics discussed included:

  • The finalized Informal Dispute Resolution (IDR) process, and
  • The finalized Hospice Special Focus Program (SFP) including selection, public reporting, enforcement, completion, and termination.

Hospice Consumer Assessment of Health Providers and Systems (HCAHPS)

The Participation Exemption for Size Form for the calendar year (CY) 2023 CAHPS Hospice Survey data collection and reporting requirements is available to complete and submit on the CAHPS Hospice Survey Web site (www.hospicecahpssurvey.org). Hospices that served fewer than 50 survey-eligible decedents/caregivers in CY 2022 (January 1, 2022 through December 31, 2022) can apply for an exemption from participation in the CAHPS Hospice Survey for CY 2023. The deadline for submission is December 31, 2023.

Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs)

On November 2, 2023, the Centers for Medicare & Medicaid Services (CMS) finalized rules related to CY2024 Payments to Physicians under Medicare. Included in the rule are regulations implementing Section 4121 of the Consolidated Appropriations Act of 2023, which allows MFTs and MHCs to serve on the hospice Inter-Disciplinary Group (IDG) and requires hospices to include one Social Worker (SW), MFT, or MHC to serve as a member of the IDG.

CMS has received many questions regarding the new regulations and will be issuing a FAQ document soon. Additionally, CMS clarified that hospice providers are not required to have MFTs or MHCs on staff but if they choose to do so these clinicians must be employees of the agency. MFTs and MHCs may serve as hospice volunteers if they meet the requirements for a volunteer at § 418.78 Conditions of participation—Volunteer.

 

Summary of CMS Open Door Forum for Home Health

NAHC Report

On November 29, 2923, the Centers for Medicare & Medicaid Services (CMS) held the Home Health, Hospice, and DME Open Door Forum. Below are key updates that provided for home health providers. Tomorrow, we will feature the summary for hospice providers. (GO HERE for the summary for hospice providers.)

Calendar year 2024 Home Health Final Rule update

Payment Update

On November 1, 2023, the CMS issued the calendar year (CY) 2024 Home Health Prospective Payment System (HH PPS) Rate Update final rule, which updates Medicare payment policies and rates for Home Health Agencies (HHAs). This rule includes routine updates to the Medicare Home Health PPS payment rates for CY 2024 in accordance with existing statutory and regulatory requirements. 

CMS is finalizing a permanent prospective payment adjustment to the home health 30-day period payment rate. The finalized -2.890 percent permanent adjustment is half the full permanent adjustment of -5.779 percent (-5.653 percent in the proposed rule). Medicare payments to HHAs in CY 2024 will increase in the aggregate by 0.8 percent, rather than decrease by 2.2 percent as proposed.

CMS finalized its proposals to rebase and revise the home health market basket and revise the labor-related share. For CY 2024, CMS will adopt a 2021-based home health market basket, which includes changes to the market basket cost weights and price proxies.

CMS recalibrated the case-mix weights and low utilization payment adjustment (LUPA) thresholds using the most complete utilization data available at the time of rulemaking. 

Disposable Negative Pressure Wound Therapy

In accordance with Division FF, section 4136 of the Consolidated Appropriations Act (CAA), 2023, CMS is finalizing its proposal to codify statutory requirements for negative pressure wound therapy (NPWT) using a disposable device for patients under a home health plan of care. The CAA, 2023 requires that beginning January 1, 2024, there is a separate payment for the device only. Payment for the services to apply the device is to be included in the 30-day payment under the home health prospective payment system. There are also changes that allow HHAs to now report the disposable device on the type of bill 32x.

Home Health Quality Reporting Program (HHQRP)

CMS is finalized the following for the CY 2025 HH QRP

  • Two new measures
  • Removed one existing measure
  • Removed of two OASIS items 
  • Begin public reporting of four measures in the HH QRP
  • Updates on closing the health equity gap
  • Codifying into regulation the 90 percent data submission threshold policy

Expanded Home Health Value-Based Purchasing (HHVBP) Model 

For the expanded HHVBP Model, CMS is finalized its proposals to:

  • Codify in the Code of Federal Regulations the measure removal factors finalized in the CY 2022 HH PPS final rule;
  • Replace the two Total Normalized Composite Measures (for Self-Care and Mobility) with the Discharge Function Score measure effective January 1, 2025;
  • Replace the OASIS-based Discharge to Community (DTC) measure with the claims-based Discharge to Community-Post Acute Care (PAC) Measure for Home Health Agencies, effective January 1, 2025;
  • Replace the claims-based Acute Care Hospitalization During the First 60 Days of Home Health Use and the Emergency Department Use without Hospitalization During the First 60 Days of Home Health measures with the claims-based Potentially Preventable Hospitalization measure effective January 1, 2025;
  • Change the weights of individual measures due to the change in the total number of measures; and
  • Beginning with performance year CY 2025, update the Model baseline year to CY 2023 for all applicable measures in the finalized measure set, including those measures included in the current measure set with the exception of the 2-year DTC-PAC measure, which would be CY 2022 and CY 2023.

CMS reminded participants that the October Interim performance reports are available and encouraged HHAs to review their reports. CMS also reminded participants of the many resources on the Expanded HHVBP website

Appeals Process

CMS finalized an additional opportunity to request a reconsideration of the annual Total Performance Score (TPS) and payment adjustment. 

CMS reminded participants that public reporting of HHVBP performance data and payment adjustments will begin in December 2024.   

Home IVIG

CMS is finalizing regulations, as proposed, to implement permanent coverage and payment of items and services related to administration of IVIG in a patient’s home for a patient with a primary diagnosis of immune deficiency disease (PIDD). Currently, Medicare pays for the IVIG product using the average sales price (ASP) methodology. Payment for items and services needed for in-home administration of IVIG for the treatment of PIDD for CY 2024 is set at $419.25.

Home Health Consumer Assessment of Health Providers and Systems (HHCAHPS)

CMS announced that registration is open for the 2024 HHCAHPS survey vendor update webinar training session. Survey vendors who wish to retain their status as approved HHCAHPS Survey vendors must have their designated HHCAHPS Survey Project Manager attend the entire session. Registration closes at 9:00 PM Eastern Time on January 30, 2024. Participants were reminded that January 18, 2023 is the 3rd quarter 2023 data submission deadline.

 

In Key Home Care Victory, House Passes Elizabeth Dole Home Care Act

McKnight’s Home care / By Adam Healy
 
Providers, industry organizations and advocates applauded the House’s passage of the Elizabeth Dole Home Care Act on Tuesday evening.
 
“It’s a good recognition, especially on the House’s part, that reinforces home care as an industry,” Jason Lee, chief executive officer of the Home Care Association of America (HCAOA), said in an interview on Wednesday with McKnight’s Home Care Daily Pulse. “They see the value in the services, and that is so critically important.”
 
The Elizabeth Dole Home Care Act would introduce various provisions to make home care more accessible for veterans. Among the key ones: The cost of providing veterans noninstitutional alternatives to nursing home services, such as home care, may not exceed 100% of the cost that would have been incurred if they had received Department of Veterans Affairs nursing home care. (Under current law, these expenditures are limited to 65% of the cost.) And for specified veterans, the VA may exceed 100% of the cost if it determines the higher cost is in the best interest of such veterans. 
 
The legislation also would create partnerships between the Program of All-Inclusive Care for the Elderly (PACE) and Veterans Affairs Medical Centers, according to the National PACE Association, which also expressed support for the bill.

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The HHVBP Changes Experts Believe Home Health Providers Are ‘Overlooking’

Home Health Care News / By Patrick Filbin
 
Several of the biggest changes in the U.S. Centers for Medicare & Medicaid Services’ (CMS) CY 2024 final home health rule deal with the Home Health Value-Based Purchasing (HHVBP) model.
 
At face value, it may seem like the HHVBP process is being simplified in the way providers fill out OASIS forms.
 
However, there’s more to it than just that.
 
“What is true today is not what’s going to be true with the final rule,” Cindy Krafft, owner of K&K Health Care Solutions, said during a MedBridge webinar on Tuesday. “I do believe that many people were so concerned about the reimbursement piece that there was not enough feedback in the open comment period about some of these other things.”
 
For instance, Krafft pointed out the HHVBP change which saw a total normative composite turn to a discharge functional score.
 
Essentially, CMS will evaluate home health agencies with an emphasis on the functional status of patients at the time of discharge from their agencies, as opposed to a comprehensive measure of various factors — including patient outcomes, processes of care and patient experience.
 
“That sounds like a great concept, but we can’t oversimplify it,” Krafft said.
 
For example, OASIS measures like eating, oral hygiene, toileting hygiene and a number of physical functionality scores are included in the new calculation.
 
What’s missing, Krafft pointed out, is bathing and dressing.
 
“There are some pretty heavy-hitting activities related to function that we have been focused on — and rightfully so — for a very long time,” Krafft said. “Even before OASIS, we knew our folks had to be able to manage bathing and dressing and meal prep and all of those things to be able to have patients be safe at home. But they’re not on this list.”
 
The reason why the list is shortened is related to the Improving Medicare Post-Acute Care Transformation Act, also known as the IMPACT Act.

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New Analysis Shows How Unaffordable Home Care Is Becoming For American Seniors

Home Health Care News / By Andrew Donlan
 
Most Americans will need some sort of in-home care support as they age. The issue is that many of them cannot afford it. 
 
To age in place, seniors either need to be completely independent or have some sort of personal care afforded to them. If they qualify for Medicaid, home- and community-based services are an option. But waitlists for HCBS in some states can be quite long
 
Medicare covers home health care, but not personal care, which generally helps seniors deal with activities of daily living. Seniors not supported by Medicaid or Veterans Affairs (VA) are left to pay out of pocket for services. 
 
Only 14% of American seniors can afford to do so, however, according to a new analysis conducted by the Joint Center for Housing Studies of Harvard University. In some markets, an even smaller percentage of seniors can afford home care. 
 
Worse yet, more than 40% of Americans 65 years and older live alone. An even larger percentage of Americans live alone once they pass 80 years old. 
 
The percentage of Americans that can afford personal care has undoubtedly shrunk over the course of the last few years. It’s a massive problem for seniors, but it’s also a problem for providers. They’ve had to grapple with billing rates rising by anywhere from 20%-40% since 2021, which generally gets passed onto clients. 
 
“The reality is that two times that bill rate is too expensive for probably 95% of Americans, or American families. Yet the need for the service that we provide is universal,” Arosa CEO Ari Medoff told Home Health Care News in June. “So 100% of the population needs what it is that we offer, and maybe 5% or 10% can afford to pay out of pocket. Maybe 10% or 20% are qualified and eligible for Medicaid services. That means that a vast majority – 75% to 85% of American families – are just struggling to provide that support that their loved one needs as they age, and that is where we see people go into assisted living or going into nursing facilities when that’s not their preferred place to age.”
 
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