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An omnibus was passed just before Christmas, and we hoped it would include an extension of the Home Health payment reductions due to the behavioral adjustment found in the final rule, but that did not take place. Below are a few items that are included in the content of that legislation that will impact both Home Health and Hospice.  

TELEHEALTH EXTENSION & RURAL ADD-ON FOR HOME HEALTH AND HOSPICE  

In Home Health, the rural add-on has been extended through 2023, but that is only for low population density areas which include few counties that would have the application of the 1% add-on of the rural adjustment. In addition to that, telehealth flexibilities have been extended for 153 days after the end of the Public Health Emergency, which potentially could end in January. This Omnibus legislation includes a significant extension on telehealth services for Face-to-Face Encounters for Home Health and Hospice which will be extended through December 31, 2024.  

CMS PAYMENT ADJUSTMENTS FOR HOME HEALTH

Regarding the CMS payment adjustments for Home Health, there is no extension on the reduction, so our rates will reflect exactly what was in the Home Health Final Rule for 2023, which includes a 3.95% reduction in the rates. There was a 4% increase in the Market Basket. That, coupled with other adjustments, brings us to just below the rates that we currently have in 2022.  

Included in this legislation, CMS is required to have stakeholder meetings that will include CMS being transparent with how they have adjusted the rates. One of the biggest concerns in Home Health is that we don’t know the exact details behind the calculations of the behavioral adjustment, and with the items that we do know more about, we do not agree with the calculations.   

AGGREGATE CAP FOR HOSPICE

There was concern that there would be a Cap reduction to the aggregate Cap for Hospice, which did not occur. There was a decision to extend the current Cap calculation methodology through 2032, which is encouraging, but we will still need to do work as MedPac is continuing to vote for a reduction in the aggregate Cap.   

The results of this legislation were not exactly what we had hoped for specifically with Home Health and the reduction of the behavioral adjustment. We will continue to fight in the coming year as the stakeholder meeting will need to be set so that full transparency can happen regarding the calculation of the behavioral adjustment. We will continue to ask for your help with advocacy in many of these areas and hope that you will be on our side. We continue to join with the state and national Home Care and Hospice Associations to fight on your behalf and challenge you to be deeply involved in those associations, and to participate in advocacy. 

If there is anything we can do to assist you in understanding exactly how that will apply to you, please don’t hesitate to let us know.