As we close out 2024, Home Health has been a rocky road at best. We expect that this will continue into 2025, but with advocacy efforts comes the potential for improvement.
We started the year with the release of the Draft OASIS-E1 and through the year the document was finalized. The OASIS-E1 Guidance manual was released late in the year and the OASIS-E1 requires full implementation January 1, 2025. All OASIS with a M0090 date of 1/1/25 and later will require E1.
The Home Health Value-Based Purchasing (HHVBP) Expansion is in full swing. At the beginning of 2024 we were receiving the Interim Performance Reports (IPR) and the analysis of 2023 data was beginning to tell the story of how the payments would be allocated for 2025. With the Home Health Final Payment Rule issued November 1, 2024 the final changes for the 2025 HHVBP Model have been established. Many of the changes include the use of GG items from the OASIS-E1, new Discharge to Community and new Hospitalization measures. Agencies are beginning to experience the payment increases or decreases to their 2025 payments resulting from the 2023 Total Performance Score results.
The release of the Home Health Final Rule brought many changes, including a payment rate update that includes a -1.975% permanent adjustment. In addition, all case-mix weights were updated, LUPA thresholds reviewed and some adjusted, Fixed Dollar Loss Ratio adjusted for Outlier Payments, and a major revamping of the CBSA classifications and corresponding wage index.
Agencies must submit OASIS data for all patients, regardless of payer, beginning July 1, 2025, and may voluntarily submit beginning January 1, 2025. We recommend beginning the OASIS all-payer data collection and submission process prior to the required date to ensure that processes, export schedules and staffing levels have been addressed well ahead of the requirement deadline.
The Home Health Final Rule also brought a new Condition of Participation to home health. This standard will appear at 484.105(i), and is titled Acceptance to Service Policy. This new standard requires the agency to develop, implement, and maintain an acceptance-to-service policy that is applied consistently to each prospective patient referral. This policy must address at a minimum:
- The anticipated needs of the referred patient
- The home health agency’s case load and case mix
- The home health agency’s staffing levels and
- The skills and competencies of the home health agency’s staff.
During 2024 home health continued to allow Face-to-Face encounters to be conducted via telehealth as an extension of the Public Health Emergency waivers was granted through December 31, 2024. On December 21, 2024, Congress passed the American Relief Act of 2025. This Act included a temporary extension of the allowance for telehealth Face-to-Face encounters for both home health and hospice. This extension is set to expire March 31, 2025.
Additional changes have occurred in 2024 regarding the BFCC-QIO information. Kepro had a name change to Acentra, and this requires that all information/documents that are communicating the BFCC-QIO information to a patient have that name change included. In addition, a new Notice of Medicare Non-Coverage Form has been released that includes an expiration date of 11/2027. This new form must be implemented January 1, 2025.
We always recommend that agencies verify payer of the patient by doing an eligibility verification every week for at least the month of January to ensure you are working with the correct payer. If the patient changed insurance during Open Enrollment, there is a huge possibility that the update to the payers did not occur by January 1.
HPS is here to assist with any and all challenges that your home health may be facing as we begin 2025. Being proactive within your home care will prohibit many of the negative consequences that may result from lack of diligent reviews. Reach out to us to learn how we can assist you in being fully prepared for what’s ahead.
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