The unveiling of the 2024 Home Health Proposed Rule, although anticipated, brought about significant disappointment. The primary source of this discontent stems from the CMS decision to fully enforce the behavioral adjustment. As you may recall, in 2023, we grappled with a 3.65% decrease in the base rate. For 2024, they suggest appropriating the remainder of the behavioral adjustment, leading to a permanent rate reduction of 5.65%.  This provides a net reduction of 2.2% following the application of the increase in the market basket and taking the productivity adjustment into account.  

It’s quite disheartening, almost akin to a slap in the face, to see a decrease in payments at a time when Home Health is one of the most vital components of healthcare, particularly within the Medicare program. The CMS has not made any substantial efforts to provide detailed explanations on how this calculation was derived, and the scant details provided do not seem logically sound. They fail to truly reflect or consider the current state of affairs within Home Health. Consequently, this Proposed Rule has led the National Association for Home Care and Hospice to file a lawsuit against CMS, specifically concerning this behavioral adjustment. Furthermore, we currently have bills in circulation that require your representatives’ approval. These bills, put forth by Senators Collins and Stabenow, aim to halt CMS from implementing these reductions until an agreed-upon methodology is adopted for the calculation.  

A couple of important links need your attention. First, a link where you can share your comments on the Proposed Rule. Second, a link that will enable you to swiftly send an email to your representatives with just a click, requesting them to endorse the bills that aim to halt the CMS regulation from slashing our rates.  

In addition to altering the rate structure, they’ve also made adjustments to all case mix weights, modified LUPA thresholds, and recalibrated the points used for functional scoring in the PDGM model. Changes have also been made to the Value-Based Purchasing model, which will take effect from January 2025, giving us a year to make necessary adaptations.  

The adjustments to the Value-Based Purchasing model comprise of the elimination of the 1800 items that make up the Total Normalized Composite change measures. Instead, a measure that will be employed or calculated at the time of discharge will utilize the GG item set from the OASIS. This shift is steering us towards a direction we’ve long anticipated, which involves removing the 1800 items from the calculation of the PDGM model as well, and replacing them with the GG items. While this wasn’t part of the current Proposed Rule, we foresee it happening in the near future.  

I say that to say the GG items have been ignored by many agencies and not a huge emphasis put on making sure that education surrounding the GG items occurred within your organization. Please don’t let that be one of the biggest mistakes that your agency makes. Please make sure your field staff understand fully the significance of the GG items and now that they will specifically be used in calculations of measures in the Value-Based Purchasing model.     

HPS has an upcoming webinar scheduled for next Thursday, focusing on the 2024 Home Health Proposed Rule. During the webinar, we will thoroughly examine and discuss the various details outlined in the Proposed Rule. This will help you better understand and prepare for the final rule, which is set to be issued in November. We highly encourage you to join us for this informative session. To register for the webinar, please check your email for the provided link.  

Lastly, many of the state and national associations are still to have conferences this summer and fall at each of those, they will be discussing this Proposed Rule and what action you can assist them in taking to help stop it. Please make sure you do participate. 

Should you have any further questions regarding the reports or Value-Based Purchasing overall, and if HPS can assist you, please feel free to get in touch.   

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