The Home Health Final Rule for 2024 was published on November 1, 2023, and with it comes many changes. Most of the outlined changes in the 531-page document will go into effect starting on January 1, 2024. A high-level, summarized review of the changes in the 2024 Home Health Final rule can be examined below.
PERMANENT BEHAVIORAL ADJUSTMENT
Changes to the rule begin with the permanent behavioral adjustment, which initially proposed a decrease of 5.65%. However, after recalculating, CMS decided to only take half of the remaining portion this year, resulting in a 2.890% adjustment. This adjustment will be offset by the increase of 3% in the Market Basket, resulting in a slight overall increase.
While legislation is trying to be pushed through and legal action is being pursued against CMS, ongoing disappointment remains as the permanent behavioral adjustment still exists.
PROPOSED/FINALIZED BASE RATES
In July, it was initially proposed that the CY 2024 National Standardized 30-Day Period Payment base rate would be $1,974.38, due to the 5.65% proposed reduction. Considering the 2.89% behavioral adjustment and the 3% increase in the Market Basket, the resulting base rate is $2,038.13. This revised rate is an improvement compared to the original proposal.
2024 LUPA FINAL RATES
The behavioral adjustment that reduces the base rate does NOT impact the LUPA (Low Utilization Payment Adjustment) rates and the LUPA rates are increased by the full 3% Market Basket increase. The rates reflected are bases rates and will need to be wage-adjusted based on where a patient receives care.
All 432 case-mix weights of the PDGM HIPPS codes have been recalibrated using 2022 data. This recalibration can significantly impact payments. It is crucial to take these changes in case-mix weights, along with the base rate change, into consideration.
The Fixed Dollar Loss (FDL) ratio used in the calculation of the Outlier payment has been revised. In 2024, it will change from .35 or 35% to .27 or 27% of the calculated agency’s cost that needs to be absorbed before an Outlier is triggered.
The Labor Share proposed change did not see much activity from the proposed rule due to all the disturbance created by the behavioral adjustment. The Labor Share is currently 76.1%. Starting in 2024, it will be changed to 74.9%. Calculations of agency payments are determined by using a calculation of the base rate multiplied by the case-mix weight and then multiplied by the labor share % and followed by the wage index. (See the examples of the calculation in the video). Agencies with a wage index of less than 1.0 benefited from this change, as it means they have to wage adjust a lesser portion of the base rate.
FUNCTIONAL STATUS CHANGES
Also included in the Final Rule were functional status point changes, which included reductions in allocated points in the following items:
- M1820: Current Ability to Dress Lower Body
- M1830: Bathing
- M1860: Ambulation
- M1033: Risk of Hospitalization (increase of 1 point)
CMS has made ongoing adjustments to these functional scoring items with the aim of maintaining a balance of 33% in each of the low, medium, and high functional status categories. However, high functional status remains dominant.
DISPOSABLE NEGATIVE PRESSURE WOUND THERAPY (dNPWT)
The Disposable Negative Pressure Ulcer Wound Therapy is subject to billing changes. Currently, this treatment and the device must be billed on a 34x bill type. However, starting on January 1, 2024, it will be billed on the home health claim. Additionally, nursing visits will be billed as a routine visit, and dNPWT devices will be billed using the HCPCS code A9272. The reimbursement for each device billed using HCPCS code A9272 will be $270.09.
M ITEMS TO BE REMOVED FROM OASIS-E
The items “M0110 Episode Timing” and “M2200 Therapy Need” will be completely removed from OASIS-E starting January 1, 2025.
HOME HEALTH QRP
The following four measures will begin to be publicly reported:
- Discharge Function
- Transfer of Health (TOH) Information to the Provider – Post-Acute Care (PAC) Measure (TOH Provider)
- Transfer of Health (TOH) Information to the Patient – Post-Acute Care (PAC)
- COVID-19 Vaccine: Percent of Patients/Residents who are up to date
The COVID-19 vaccine item will need to be reported on the Discharge, Transfer, and/or Death at Home OASIS. This requires adjustments to OASIS in order to answer these specific questions. Uncertainty remains regarding the exact interpretation of what “current vaccine status” really means and clarification from CMS will be required.
PROPOSED 2025 HOME HEALTH VALUE-BASED PURCHASING MODEL CHANGES
The Home Health Value-Based Purchasing Model will undergo several changes starting in January of 2025. Changes include the removal of five measures with the addition of three replacement measures, updated weights for all measures except HHCAHPS, and an updated baseline year for all measures. (See video for details). The Final Rule presents current measure weights changes, and their proposed changes for both the large- and small-volume cohorts. It’s important to note that the Value-Based Purchasing Model for 2024 will remain unchanged from its current state.
On November 20, Healthcare Provider Solutions will host HPS Home Health Final Rule, a detailed webinar featuring Melinda A. Gaboury, CEO. In the webinar, Melinda will provide a detailed review of the 2024 Home Health Final Rule, including changes that are set to be implemented in 2024/2025, best practices for implementation, and updates to the Value Based Purchasing Expansion. To reserve your spot and attend HPS Home Health Final Rule, click here.
Should you have any questions about the newly released 2024 Home Health Final Rule, please feel free to reach out to us.
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