2015 Home Health Proposed Rule – Summarized

September 30, 2014

On Monday, July 7th, CMS Released the Proposed Rule to affect agencies starting in calendar year 2015. You can find a copy of the full text here.

We here at therapyBOSS thought you might prefer a short summary over a 56 page document in itty bitty print so here we go.

Let’s start with the most relevant proposed change of 2015 for therapists. Therapy reassessment visits which now must be done every 13th and 19th visit and at least every 30 days may be changing to being required every 14 calendar days for each discipline. While this will make it much easier to track individual disciplines and eliminate problems with communicating missed visits and calculating exact 13th and 19th visits, it could potentially create a greater paperwork burden for therapists as every 14 calendar days could be more frequent than the old model – especially in single-therapy cases. Of course, therapyBOSS will eliminate this burden, just as it does presently, by generating the functional reassessment note based patient’s documented progress and completed functional assessment tests.

CMS also proposes clarifying the qualifications of a Speech-Language Pathologist to ensure that personnel providing this service to Medicare beneficiaries are either state-licensed or satisfy more specific experience criteria including 350 clock hours of supervised clinical experience, nine months of supervised full-time services after obtaining a master’s or doctoral degree, and completion of a national Secretary-approved Speech Language Pathologist exam.

As happens every year, the reimbursement rates are changing. There is a lot of information here but basically the proposed rule would decrease the standardized 60-day payment amount by $80.95 for the rebasing adjustment and increase it by 2.2% for the market basket increase. There is also a planned increase in reimbursement for 0-5 therapy visit episodes and decreased reimbursement for larger numbers of therapy visits in an episode. Some CBSA areas are proposed to be changing so agencies need to keep an eye on that when it comes to billing. The grouper calculation system is expected to be updated as well as diagnoses that contribute to points in the clinical domain with some conditions (such as blindness and psych) no longer contributing points to the clinical domain at all. It is generally thought that overall reimbursement will decrease for home health agencies, but because of the massive changes it is hard to predict the exact impact these reimbursement changes will have.

CMS is also proposing changes to the face-to-face requirement. It is a common complaint in the industry that mandating physician narratives on the face-to-face with no clear instructions and no incentive for compliance has created an impossible situation for the home health industry. CMS is attempting to address this complaint in the new rule by only requiring the agencies to maintain the attestation that the visit was done and the date it was completed. However, it has been pointed out that celebrations may be premature as the physician still needs to maintain clinical records that justify ordering home health care and that a home health claim could potentially be denied based on insufficient physician documentation maintained in the physician office.

The proposed rule attempts to provide a list of diagnoses that could indicate when a patient is unable to self-inject insulin. It appears that some agencies are unclear about what diagnoses support assisting patients in injecting insulin. It is important to remember that the patient not only should have one of the qualifying diagnoses, but that the diagnosis must be included in the claim sent to Medicare to ensure justification of why these services are being provided.

Last, but not least, CMS is considering a Value-Based Purchasing (VBP) Model for HHAs. VBP takes into consideration an agency’s statistics in select quality measures and adjusts payment based on how much better or worse those numbers are than a set standard. An agency that performs above an established threshold in quality measures would be rewarded by increased reimbursement while an agency that performs below the threshold would see a monetary penalty assessed on their claims. There is also a plan to reward improvement in performance. The plan proposes rolling out this program in five to eight select states and requiring mandatory participation by all HHAs within those selected states. The target start time will be calendar year 2016 and the anticipated payment impact would be around 5 to 8 percent. Now more than ever it is essential that every agency has a Quality Improvement plan and that agencies are looking at their data and choosing areas of underperformance and attempting to improve those metrics. Therapy will without a doubt be an important aspect of any such plan. Consequently, contract therapy providers vying for home heath therapy staffing business will need to take this into consideration. Those who want to excel will be able to demonstrate their optimal performance on the basis of outcomes.

You can expect therapyBOSS to implement the 2015 home health proposed rule as it pertains to contract home health therapy. You should also be looking forward to exciting new capabilities with regards to outcome measurement and monitoring. More on that will be provided in our upcoming update notes and blog posts.

Home Health Strategic Management (HHSM) run by Arnie Cisneros further details value-based purchasing in this article.