CMS proposes payment changes to HH services for 2011

CMS is proposing major changes in therapy qualifications, documentation and “effectiveness” of therapy in the 2011 proposed HHPPS rule. It is also proposing case-mix changes and payment changes.

This post gives an overall view and focuses on payment aspects.

The Centers for Medicare & Medicaid Services (CMS) announced late last week in its Home Health Prospective Payment System Rate Update for Calendar Year 2011 Proposed Rule a number of changes for HHAs and Hospice regarding certification, case-mix, therapy and skilled service documentation and requirements, and payment rates.

The proposed rule has a 4.75 percent decrease in Medicare payments to home health agencies (HHAs) for calendar year (CY) 2011. Based on updated data analysis, instead of the planned 2.71 percent reduction for CY 2011, CMS proposes to reduce HH PPS rates by 3.79 percent in CY 2011 and an additional 3.79 percent in CY 2012.

The agency estimates that this could be a $900 million decrease compared to payments HHAs received in CY 2010.  The decrease is a combination of market basket update, a wage index update, reductions to the home health prospective payment system (HH PPS) rates and other factors.

The Affordable Care Act (ACA) mandates a 1 percentage reduction to the CY 2011 home health market basket amount. The ACA also changes the existing home health outlier policy through a 5 percent reduction to HH PPS rates, with total outlier payments not to exceed 2.5 percent of the total payments estimated for a given year.

Among the proposals that could help lower payments is a proposal to pull two hypertension codes, 401.9 and 401.1, from the case-mix list. CMS is also proposing far more specific, and restrictive language regarding therapy. The proposals include clarifications on the roles and duties of therapists and assistant, specifics on therapy for rehabilitation or maintenance that moves toward written goals, that all therapy visits must be considered reasonable and necessary, and what constitutes assessment, documentation and goals.

“The new HH PPS provisions will help ensure more accurate payments under Medicare and reflect prudent financial stewardship of the Medicare Trust Fund,” said Jonathan Blum, director of the Center for Medicare and deputy administrator for CMS.

In CY 2010, CMS finalized a policy that requires HHAs that change ownership within three years of initial enrollment to obtain a new State survey or accreditation.  CMS now proposes exceptions to the 36-month provision for certain types of ownership transactions.  CMS is also clarifying the quality reporting requirements for the CY 2012 HH PPS rate update, as it relates to the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) Survey.

Home health payment rates are updated annually by the home health market basket percentage increase.  CMS uses the home health market basket index, which measures (and tracks) inflation in the prices of an appropriate mix of goods and services included in home health services.

Read my post on the HTN case-mix proposal.

Read my post on proposed documentation and therapy roles.

Read about CMS’s specific skilled services wording aimed at reasonable and necessary therapy.

Find out more at www.healthcare.gov.

Read the full proposed rule.

Comments are being accepted until Sept. 14 on this proposed rule, CMS-1510-P. To send comments, go to http://www.regulations.gov.  Follow the instructions under the “More Search Options” tab.

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One Comment to “CMS proposes payment changes to HH services for 2011”

  1. PT/INR’s are not a skill, just as venipuncture is not a skill. Teaching disease process, related to anticoag therapy, monitoring response to medications and teaching dosage, diet would be a skill.

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