CY2021 Home Health Final Rule

Power Point presented on 11/5/2020 by Bill Dombi, Esq., President, National Association for Home Care & Hospice and Mary Carr, Vice President, Regulatory Affairs, National Association for Home Care & Hospice

To register for audio: https://www.nahc.org/meetings-education/webinars/

Medicare HH 2021 Final Rule

  • CY 2021 Home Health Prospective Payment System Rate Update and Quality Reporting Requirements-Final Rule

  • https://public-inspection.federalregister.gov/2020-24146.pdf

  • 2.0% rate update (net at 1.9% after budget neutrality adjustment with wage index)

    • Maintains PDGM case mix model and LUPA thresholds

    • New wage index areas with 5% cap on reductions

    • Outlier standards maintained

    • No new behavioral adjustment

  • Telehealth use standards made permanent

  • 2021 Home infusion therapy payment standards and supplier requirements clarified

  • HHVBP minor modifications

  • $390M increase in Medicare spending expected

  • Should bring a degree of stabilization and predictability

2021 Final Payment Rates

  • Base payment rates are increased by a net Market Basket Index of 2.0%

    • An annual inflation update of 2.3%

    • Reduced by a 0.3% Productivity Adjustment to net at 2.0%

    • Wage index neutrality adjustment at 0.9999

    • Proposed increase of 2.7% reduced due to use of more recent 2Q2020 data

  • No change in 2020 behavioral adjustment (4.36%) as CMS wants full year of data to assess whether budget neutrality

  • Medicare home health services spending projected to increase by $390 million in CY 2021

  • The base 30-day payment rate is increased from $1864.03 to $1901.12

  • The LUPA per visit rates are set at:

    • SN $152.63

    • PT $166.83

    • SLP $181.34

    • OT $167.98

    • MSW $244.64

    • HHA $69.11

  • LUPA rates are also reduced by 2% for those HHAs that did not submit required quality data.

  • The LUPA add-on for LUPA only patient continues.

    • For example: SN as the first LUPA visit, the add-on results in a first visit payment of $281.62

    • Each discipline would get its own add-on rate

  • Area Wage Index that applies based on the patient’s residence has changed significantly to reflect update census information

    • https://www.cms.gov/medicaremedicare-fee-servicepaymenthomehealthppshome-health-prospective-payment-systemregulations/cms-1730-f

    • New CBSA inclusions and exclusions

    • New Rural and non-rural areas

    • Some CBSAs and rural areas will have more than one county-based wage index value

  • Due to the significant change, CMS proposes to cap any reduction in the wage index at 5% for 1 year

  • There is no cap on wage index increases

  • Outlier standards unchanged

    • Fixed Dollar Loss ratio stays a 0.56

    • Means that no increase or decrease in the national volume of outlier episodes is expected

  • Rural add-on phase-out continues

    • High Utilization areas — 0% add-on

    • Low Population Density areas — 2% add-on

    • All other areas — 1% add-on

  • PDGM case mix weights unchanged from 2020

  • LUPA thresholds stay at the 2020 levels

No-Pay RAP and NOA

  • RAP phase-out continues

  • CMS continues policy on 2021 No-Pay RAP and 2022 Notice of Admission

  • 5-day window for timely submission

  • Penalty for late submission applied starting with day 1 of the episode

    • number of days since episode start to submission date/ 30 X Episode Payment

Telehealth

  • Permanently allows the use of remote patient monitoring, other telecommunications, or audio-only technology

  • Tied to patient specific needs identified in the comprehensive assessment

  • Do not need to describe in the POC how the use of telehealth will help to achieve goals, but expect to see such throughout the medical record

  • Cannot substitute for an ordered home visit

  • Cannot be considered a home visit for eligibility or payment

  • Continue to report as administrative cost

  • The CARES Act requires the Secretary to encourage the use of telecommunications systems including remote patient monitoring ..and other communications or monitoring services…

RULE CHANGE

§409.46 Telecommunications technology

…………………………………………………………………………………………….

  • (e) Telecommunications technology. Telecommunications technology, as indicated on the plan of care, can include: remote patient monitoring, defined as the collection of physiologic data (for example, ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient or caregiver or both to the home health agency; teletypewriter (TTY); and 2-way audio-video telecommunications technology that allows for real-time interaction between the patient and clinician. The costs of any equipment, set-up, and service related to the technology are allowable only as administrative costs. Visits to a beneficiary's home for the sole purpose of supplying, connecting, or training the patient on the technology, without the provision of a skilled service, are not separately billable.

HHVBP

  • Modifications to align HHVBP Model data submission requirements with any exceptions or extensions granted for HH QRP during PHE

  • Modification of policy for granting exceptions to the New Measures data reporting during PHE

Home Infusion Therapy Supplier

  • New Part B benefit-coverage and payment finalized in the 2019-20 HHPPS rules

  • Covers the professional services related to HIT for Part B drugs- infused via a pump

  • HIT suppliers must be accredited by a Medicare approved AO

  • HHAs may become HIT supplier

  • HHAs may contract with a HIT supplier

  • Skilled services related to Part B infusion drugs carved out of the home health benefit beginning 1/1/2021

    • Services related to drugs outside this benefit may continue under HH benefit

  • Currently DME suppliers with pharmacies are able to bill under the new benefit

Home Infusion Therapy

  • Maintain definition of covered “home infusion drugs”

  • Three payment categories

  • Category payment amount consistent with six CPT infusion codes, equal to 5 hours in a physician’s office

  • First visit subject to payment increase, reduces rate for later visits

  • Payment for each infusion drug administration calendar day

  • Rates adjusted geographically using GAF

  • Rates updated annually by (CPI-U – productivity adjustment

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Home Infusion Therapy Supplier

Rule outlines the provider enrollment requirements

  • Accredited by a CMS approved accrediting organization

  • Comply with the conditions for payment and coverage under §414.1500- 1550 and §486.500-525

  • Submit Form CMS-855B application

  • Subject to the application fee (2020 - $595.00)

  • Limited risk level category for screening

  • Same appeal rights for enrollment denials and revocations

HHAs should begin working with DME and HIT supplier

Quality Reporting Program & OASIS

  • No changes to HH QRP for CY2021

  • Change in OASIS testing for new agencies

    • Eliminate the testing requirement due to iQIES

  • Reminders

    • OASIS-E delayed until January 1st of the year that is at least 1 full calendar year after the end of the COVID-19 PHE

    • 20 measures for CY2022 HH QRP finalized last year

Contact Information

Bill Dombi, Esq., President National Association for Home Care & Hospice

wad@nahc.org

Mary Carr Vice President, Regulatory Affairs National Association for Home Care & Hospice

mkc@nahc.org

Becky Crabtree