Guidebook of Policies and Procedures for Pre-Rulemaking Measure Review (PRMR) and Measure Set Review (MSR)

The Guidebook of Policies and Procedures for Pre-Rulemaking Measure Review (PRMR) and Measure Set Review (MSR) is now available for public comment.  The Guidebook was developed as part of a CMS-funded contract, the National Consensus Development for Strategic Planning and Healthcare Quality Measurement. It provides an overview of the PRMR (previously conducted via the Measure Applications Partnership) and MSR policies and procedures, associated timelines, measure selection and removal criteria, a summary of the committee compositions, and how committees will be engaged. We will host an informational session on July 10^th 2-4 pm EST to discuss the Guidebook prior to closing the public comment period. You can register here.

Please submit comments by visiting the Partnership for Quality Measurement website.

Public comment will remain open for 30 days, closing at 11:59 PM ET on July 21. If you have any questions about the comment submission process, please contact [email protected].

[Updated] CMS Proposes 2.2% Decrease To Home Health Provider Medicare Payments in 2024

Home Health Care news | By Andrew Donlan

The U.S. Centers for Medicare & Medicaid Services (CMS) published its FY 2024 home health proposed payment rule Friday. 

For next year, CMS is proposing to decrease aggregate home health payments by 2.2%, or an estimated $375 million less compared to 2023 levels. The draft is expected to be officially published in the Federal Register on July 10.

The news is an expected but disappointing development for home health providers.

“The $375 million decrease in estimated payments for CY 2024 reflects the effects of the CY 2024 proposed home health payment update percentage of 2.7% ($460 million increase), an estimated 5.1% decrease that reflects the effects of the permanent behavioral assumption adjustment (-$870 million) and an estimated 0.2% increase that reflects the effects of an updated FDL ($35 million increase),” CMS wrote in the draft.

A -3.925% permanent rate adjustment was already implemented in 2023.

Yet another round of payment cuts are likely to have devastating effects on the home health industry at large.

“We continue to strenuously disagree with the budget neutrality methodology that CMS employed to arrive at the rate adjustments,” William A. Dombi, the president of the National Association for Home Care & Hospice (NAHC), said in a statement shared with Home Health Care News. “Overall spending on Medicare home health is down, fewer patients are receiving care, patient referrals are being rejected because providers cannot afford to provide the care needed within the payment rates, and providers have closed their doors or restricted service territory to reduce care costs. If the rate was truly budget neutral, we would not see these actions occurring.”

In order to curb future rate cuts – including in 2024 – Sens. Debbie Stabenow (D-Mich.) and Susan Collins (R-Maine) introduced the Preserving Access to Home Health Act of 2023 earlier this month.

If passed, the bill would strip CMS of some of its payment-rate setting power. It would also force The Medicare Payment Advisory Commission (MedPAC) to consider Medicare Advantage (MA) payment rates in its reports.

“We now turn to Congress to correct what CMS has done and prevent the impending harm to the millions of highly vulnerable home health patients that depend and will depend in the future on this essential Medicare benefit,” Dombi said...

Read Full Article to see what else is in the proposed rule. 

Hospice Impacted by Home Health Proposed Rule

CY 2024 Home Health Prospective Payment System Rate Update; Home Health Quality Reporting Program Requirements Have Been Posted

Summary at a Glance

Today, in the 4:15 p.m. ET posting of the Federal Register for June 30, 2023, the Calendar Year (CY) 2024 Home Health Prospective Payment System Rate Update and Quality Reporting Program Requirements proposed rule was posted to the public inspection part of the Federal Register. Hospice provisions were included in this CY 2024 Home Health rule because CMS had additional proposed regulatory text to include. This text was either developed since the Hospice Wage Index proposed rule was published, or some details were not ready at the time of the hospice rule publication. The Home Health rule is an alternative to allow additional proposed hospice provisions to be included in the same rulemaking year.

Key Sections of this proposed rule include:

Hospice Informal Dispute Resolution process, allowing a hospice with condition-level deficiencies seeking recertification to have an informal opportunity to resolve disputes related to survey findings.

Special Focus Program proposed implementation regulations, including an algorithm for admission to the special focus program (SFP), requirements while enrolled, process for graduating from the SFP and termination from the Medicare program.

Provider Enrollment proposed changes, including:

• Highest level of screening for newly enrolling hospice providers
• Fingerprinting requirements for all 5 percent or greater owners
• Deactivation for 6 months of Medicare non-billing

Ownership Requirement:

• The rule proposes to add hospice to the change in majority ownership now required for home health agencies.
• Adds hospice to the HHA “36 month” rule – if the change in ownership occurs within 36 months after the effective date of the HHA’s or hospice’s initial enrollment in Medicare or within 36 months after the effective date of the HHA's or hospice’s most recent change in majority ownership, the provider agreement and Medicare billing privileges do not convey to the new owner.

NHPCO has begun the review of the proposed rule and will release a detailed analysis of the proposed rule and its components in the coming days. Any questions can be directed to [email protected] with ‘CY 2024 Home Health proposed rule’ in the subject line

NAHC: Medicaid Unwinding May Have Affected Thousands of Home Care Patients

McKnight’s Home Care | By C. Max Bachmann

Officials with the Department of Health and Human Services (HHS) said Tuesday they have urged states to adopt flexibilities to minimize Medicaid coverage loss during the unwinding of the continuous enrollment provision.

Between 8 million and 24 million people could lose Medicaid coverage during the 12-month unwinding period, according to data from KFF. The concern, CMS and home care providers say, is not that these beneficiaries are no longer eligible, but rather that procedural roadblocks are stopping them from receiving coverage.

“The biggest challenge and concern we have is not that home care clients will be determined ineligible — though it will happen on a minimal basis — it is that the individuals will be disenrolled for procedural reasons,” National Association of Home Care & Hospice Director of Medicaid HCBS Damon Terzaghi told McKnight’s Home Care Daily Pulse in an email.

These procedural reasons include everything from beneficiaries changing addresses to losing forms in the mail to simply lacking information on the renewal process. As a result, HHS urged states to extend enrollment time frames and partner with local governments and community organizations to make information more accessible to Medicaid and CHIP eligibles. 

HHS also urged states to adopt strategies and federal waivers it has proposed over the past year-and-a-half that make the renewal process easier, including in some cases, having the process be automatic. 

On Monday, HHS offered new flexibilities including allowing managed care plans to assist people with Medicaid in completing their renewal forms and allowing states to delay administrative termination by a month to give people more time to fill out and return these forms…

Read Full Article