2025 Home Health Proposed Rule

On June 26, 2024, CMS released the 2025 Home Health Proposed Rule, and with it comes some rather disheartening news. As anticipated, the Proposed Rule outlining the 2025 rate adjustments for home health has been released, and unfortunately, it includes another reduction to our permanent base rates.

PROPOSED PAYMENT ADJUSTMENT

Since the implementation of the PDGM model in 2020, CMS has continued to apply a flawed budget neutrality adjustment in the rate reduction calculations. For 2025, they are proposing a decrease of just over 4% in the permanent rates.

This reduction is slightly mitigated by a 2.5% increase in the Market Basket, factoring in a productivity reduction. Overall, changing our permanent 30-day payment rate from $2,038.13 to $2,008.12. This decrease would lead to a reduction of over $280 million in home health payments in the year 2025.

Senators Stabenow and Collins are continuing their advocacy for home health by introducing Bill S.2137, which aims to eliminate these rate cuts. We need your support to encourage your representatives to endorse this legislation. It is crucial to take action against ongoing CMS rate cuts, which threaten the future of home healthcare. Without intervention, these reductions could ultimately lead to the collapse of home healthcare services.

To read more about Wage Index and CBSA Classification Changes in the 2025 Home Health Proposed Rule, Click here.

LUPA RATES

Alongside the base rate cut, they have raised the LUPA rates, reflecting the increase in inflation. This adjustment is based on the Market Basket minus the Productivity Measure, resulting in a 2.5% net increase in the per visit LUPA rates.

Additionally, a new LUPA add-on factor specific to occupational therapy will be implemented on January 1, 2025. For the past two years, they have been using the physical therapy add-on factor.

HOME HEALTH QUALITY REPORTING PROGRAM

In this proposed rule, they have made detailed requests for information related to the Home Health Quality Reporting Program. They are seeking input on additional social determinants of health data and other measures that may be proposed for future implementation. However, none of these changes would take effect in 2025.

HOME HEALTH VALUE BASED PURCHASING MODEL

For the Home Health Value-Based Purchasing Model, all changes for 2025 were finalized in the 2024 rule. In the proposed rule for 2025, they are requesting feedback on potential new value-based purchasing measures that could be implemented in 2027. At this stage, it is only a request for information. They are also discussing the possibility of adding a new Condition of Participation (CoP) focusing on decisions around accepting referrals and related policies. They seek input from your organizations on specific factors influencing your decision to take on patients, issues related to access to care, and any instances where rate changes have caused patients to suffer from access problems. If your agency has experienced such issues, it is crucial to submit this information.

Recently, CMS released Preview Annual Performance Reports for the HHVBP Model.Click here to read more.

REHAB THERAPY

Discussion has commenced, and input is being requested, on the idea of allowing registered therapists to conduct the Start of Care Assessment in home health, even when skilled nursing is ordered. Since the implementation of OASIS, it has been a long-standing rule that nursing must perform the Start of Care if both therapy and nursing are ordered. This request for information aims to evaluate whether therapists should be permitted to conduct the Start of Care Assessment, even when nursing services are involved.

They also mentioned that the rates for Disposable Negative Pressure Wound Therapy (DNPWT) and IVIG will be published in the final rule. Additionally, they are proposing a change to the definition of a new provider or supplier. This change would include any provider that has had a deactivated Medicare number and has gone through the process of reactivating it. These providers would be classified as new providers and would be subject to any additional scrutiny or reviews associated with being a new provider.

To read more about Mandatory OASIS Requirement clarifications in the 2025 Home Health Proposed Rule, Click here.

The Home Health Proposed Rule is detailed and spans over 250 pages. You have until August 26 to provide your comments on the Home Health Proposed Rule. To view the legislative information we ask you to help us advocate for with your representatives, click here.

HPS will be hosting a FREE nationwide webinar on July 25 discussing the information included in the Home Health Proposed Rule. To register for this webinar, click here.

In addition to the free webinar hosted by HPS, The National Association for Home Care and Hospice will offer a nationwide webinar that will also cover the Home Health Proposed Rule. To register for this webinar, click here.

We must persist in our efforts to oppose the ongoing cuts imposed by CMS on home health, ensuring we can always care for patients in their time of need. Should you need assistance in understanding or commenting on the Home Health Proposed Rule, HPS is here to help. Please feel free to reach out to us.

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