FutureFocus July 11, 2018: Policy Reshaping Telehealth Reimbursement

Lisa Remington

In this week’s FutureFocus, are new discussions and trending insights about how policy is supporting the use of telehealth for all providers. This is a big breakthrough for patient care management and oversight. Threaded into the new announcement about 2019/2020 Medicare reimbursement updates for home health agencies is a glimpse of the future of telehealth. Be sure to read how telehealth can broaden your organization’s internal and external growth and partnerships.

Lisa Remington, President, Remington Health Strategy Group

By: Ronald M. Schwartz, Writer, The Remington Report

The Centers for Medicare & Medicaid Services projects that Medicare payments to HHAs in CY 2019 would be increased by 2.1 percent, or $400 million, based on the policies in the agency’s proposed PPS regulation issued July 2.

 The proposed increase reflects the effects of a 2.1 percent home health payment update percentage ($400 million increase); a 0.1 percent increase in payments due to decreasing the fixed-dollar-loss (FDL) ratio in order to pay no more than 2.5 percent of total payments as outlier payments (a $20 million increase); and a -0.1 percent decrease in payments due to the new rural add-on policy mandated by the Bipartisan Budget Act of 2018 for CY 2019 ($20 million decrease).

The new rural add-on policy requires CMS to classify rural counties into one of three categories based on: 1) high home health utilization 2) low population density and 3) all others. Rural add-on payments for CYs 2019 through 2022 vary based on counties’ category classification.

New Patient Groupings Model Proposed

As required by the Bipartisan Budget Act of 2018, the proposed rule would also implement a new Patient-Driven Groupings Model (PDGM) for home health payments. The PDGM would eliminate the use of “therapy thresholds” in determining payment and changes the unit of payment to 30-day periods of care. The PDGM would be implemented in a budget-neutral manner on January 1, 2020.

Said CMS Administrator Seema Verma: “The redesign of the home health payment system encourages value over volume and removes incentives to provide unnecessary care.”

Other aspects of the proposed rule:

  • Eliminate the requirement that the certifying physician estimate how much longer skilled services would be needed when recertifying the need for continuing home health care;
  • Allow the cost of remote patient monitoring to be reported by HHAs on the Medicare cost report form;
  • Discusses the implementation of temporary transitional payments for home infusion therapy services to begin on January 1, 2019;
  • Solicits comments regarding payment for home infusion therapy services for CY 2021 and subsequent years;
  • Proposes health and safety standards for home infusion therapy; and proposes an accreditation and oversight process for home infusion therapy suppliers.

The HH QRP section of the rule discusses the Meaningful Measures Initiative and proposes the removal of seven measures. In addition to providing an update on the progress towards developing public reporting of performance under the Health Value-Based Purchasing (HHVBP) Model, CMS proposes to refine the HHVBP Model.

The proposed rule is scheduled for publication in the July 12 Federal Register. Deadline for public comments is COB August 31. For the three-page CMS Fact Sheet on the proposed regulation, click here.

NAHC Early Reaction: New Groupings Model “Warmed-Over” HHGM Design

“An early review” of the CMS proposal “indicates” it “needs more work,” said Bill Dombi, National Association for Home Care & Hospice (NAHC) president, shortly after the rule was issued. Regarding the new Patient-Driven Groupings Model (PDGM), “it appears that the 2020 model is a modestly adjusted and ‘warmed-over’ version of the highly criticized Home Health Groupings Model re-labeled as the Patient-Driven Groupings Model. Many of the same weaknesses present” in the 2017 proposed and withdrawn HHGM “exist in this new version.”

“NAHC remains very concerned that the new model still includes a significant ‘behavioral adjustment’ based on assumptions that would trigger a 6.42% reduction in base payment rates. Many of these assumptions are driven by CMS’ design with unnecessary changes to the current model. We do not want to prematurely judge the 2020 version of payment reform as it is complex, detailed, and will require deep analysis. However, we are concerned that CMS may have been relegated to using too much from its HHGM design because CMS is pressed by a deadline.”

“We would note that the draft rule also contains very important other proposals including the implementation of the home infusion therapy benefit and improvements to the claims processing standards to permit greater inclusion of home health agency records in reviewing eligibility for Medicare benefits.” As with others, additional comments will be made through the rulemaking process.