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The Breaking News that has every one full of excitement and hope is that the 2018 Home Health Final Rule does NOT include finalizing HHGM, at this time, which was set for implementation in 2019! The battle has been won, BUT the war has just begun! Some form of payment reform will occur in home health. It is not known at this point what it will look like or what year it will take place. To read more about HHGM, please refer to our 2018 Proposed Rule article.
The Centers for Medicare and Medicaid Service (CMS) released the CY2018 Medicare Home Health FINAL payment rule November 1, 2017. The FINAL rule is posted here. The 2018 final changes to home health prospective payment rates are the typical changes that have been occurring for the last few years.
The home health Market Basket Index inflation update for 2018 is preset at 1% along with the suspension of the annual Productivity Adjustment. The 1% update is offset with the 0.97% case mix creep adjustment that was promised last year. The finalized base episode rate for 2018 is set at $3,039.64. The base rate is only the beginning of the adjustments. CMS proposes a recalibration of the case mix weights again in 2018. The LUPA rates will increase 1% because the case mix creep adjustment does not affect the LUPA rates. Non-routine medical supply rates are also adjusted by 1%.
With respect to outlier payments, CMS finalized keeping the same 80% loss ratio that has been in use since the beginning of HHPPS and maintain the Fixed Dollar Loss Ratio at 0.55. The 3% Rural Add-On is not included in the 2018 proposed rule, but is a part of a separate piece of legislation, including being extended for 5 years and is probable to be passed by year end. It is currently set to expire at the end on 2017. The final rule includes a continuance of the 2% rate reduction for HHAs that fail to comply with the quality data submission requirements surrounding OASIS and HHCAHPS.
Value Based Purchasing (VBP) UPDATE
- Home Health Care Consumer Assessment of Healthcare Providers and System (HHCAHPS) Surveys – finalized changing the required number of completed surveys returned in order to calculate a performance score. This change has be retroactively applied to the FIRST performance year (2016), which affects payments for 2018
- The final rule finalized the removal of the OASIS-based measure – Drug Education on All Medications Provided to Patient/Caregiver during All Episodes of Care. This measure will be removed beginning with performance year 3 (2018).
Home Health Care Quality Reporting Program (HH QRP) UPDATE
- CMS continues to seek public comment on which social risk factors might be most appropriate for reporting stratified measure scores and potential risk adjustment of a particular measure. Examples: dual eligible/low-income subsidy, race and ethnicity and geographic area of residence.
- The rule finalized the Data Elements for removal from OASIS – 247 data elements from 35 OASIS items collected at specific time points will be removed. These elements are not used in the calculation of quality measures nor are they used for payment, survey, VBP or care planning.
The rule finalized three new Post Acute Care (PAC) setting measures under the domains in accordance with the IMPACT Act, these will require the beginning of collection to be January 2019. CMS finalized the new measures without any changes from what was included in the proposed rule.
- Skin Integrity and Changes in Skin Integrity Domain
- Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short Stay) is to be replaced with a measure entitled Changes in Skin Integrity Post-Acute Care: Pressure Ulcer/Injury
- Functional Status, Cognitive Function, and Changes in Function and Cognitive Function Domain
- Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631).
CMS proposed to begin collecting in 2019 standardized assessment data items under five domains: Functional Status; Medical Conditions and Co-morbidities; Cognitive Function and Mental Status; Special Services, Treatments and Interventions; and Impairments. CMS only finalized standardized assessment data under two of the five domains.
- CMS will apply the assessment items for the measure “Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (NQF #2631)”, to meet the requirements for this domain.
Medical Conditions and Co-Morbidities
- CMS will use elements needed to calculate the measure for pressure ulcers, such as diabetes, incontinence, peripheral vascular disease or peripheral arterial disease, mobility, as well as low body mass index (BMI), to meet the requirements for this domain.
CMS finalized the plans to begin public reporting in 2019 on the following OASIS and claim based measures that agencies began collecting in 2017.
- Percent of Patients or Residents with Pressure Ulcers that are New or Worsened;
- Drug Regimen Review;
- Medicare Spending Per Beneficiary;
- Discharge to Community;
- Potentially Preventable 30-Day Post-Discharge Readmission
Agencies need not forget about HHGM and stay tuned for further updates and be on the alert for requests to contacted your legislative representatives regarding any changes they will continue to try to implement.