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Horseplay and CMS 2017 HH PPS Proposed Rule

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I love horses, but home health agencies, patients and clinicians are more important.More on that a bit later.On Friday Aug 26th at 12:00 am EST the comment period for the 2017 Home Health PPS proposed rule closed.For the last several years CMS has been reducing reimbursement to HHAs while adding heavy regulatory burdens at the same time, the trend continued this year.The rule contained a number of provisions that will significantly impact HHAs and by proxy, home health physical therapists and physical therapist assistants.Here are some of the proposed changes for 2017:

  1. CMS will implement the last year of the four-year phase-in of the ACA mandated rebasing adjustments to the national, standardized 60-day episode payment amount, the national per-visit rates and the non-routine supplies (NRS) conversion factor.
  2. The rebasing adjustments for CY 2017 will reduce the national, standardized 60-day episode payment amount by ($80.95).
  3. The overall impact due to the rebasing adjustments is estimated to be a (2.3) percent decrease in HH PPS payments for CY 2017.
  4. CMS is proposing to require therapists to perform each and every OASIS assessment for patients with musculoskeletal conditions.
  5. CMS is proposing to change the methodology used to calculate outlier payments, moving from a cost per visit approach to a cost per unit approach (1 unit = 15 minutes).
  6. CMS is proposing to increase the Fixed-Dollar Loss (FDL) ratio from 0.45 to 0.56 in order to ensure outlier payments do not exceed 2.5 percent of total payments for CY 2017, as required by the Social Security Act.
  7. The proposed rule includes a decrease to the national, standardized 60-day episode payment amount of (0.97 percent) in CY 2017, the second year of a three-year phase-in, to account for nominal case-mix coding intensity growth unrelated to changes in patient acuity between CY 2012 and CY 2014.
  8. CMS has updated the case-mix weights using CY 2015 home health claims.
  9. Starting January 1, 2017, Disposable Negative Pressure Wound Therapy (NPWT) devices will be paid via OPPS. The amount paid to the HHA by Medicare will be equal to 80 percent of the lesser of the actual charge or the payment amount as determined by the OPPS for the year along with a 20 percent beneficiary coinsurance.
  10. In the proposed rule, CMS discussed a new performance based payment model that could replace the current HH PPS system.This model would not use the number of therapy visits to determine payments.CMS will release a technical report on this model later this year.
  11. CMS is proposing to adopt four new quality measures:
    1. Total Estimated Medicare Spending per Beneficiary – Claims Based;
    2. Discharge to Community – Claims Based;
    3. Potentially Preventable 30-Day Post-Discharge Readmission Measure – Claims Based; and
    4. Drug Regimen Review Conducted with Follow-Up for Identified Issues – Patient Assessment Based.
  12. CMS is proposing a new rule that would require PTs to utilize two objective tests (the Tinetti is specifically excluded in the rule) and continue them for the entire episode on a weekly basis.They are calling this a “pick two and be true” approach.
  13. CMS would remove 28 quality measures, beginning with CY 2017, and 6 process measures beginning with CY 2018 due to CMS determining that these measures have been “topped-out”.
  14. CMS is proposing to implement a calendar year provider review and correction periods for the OASIS assessment-based quality measures.
  15. CMS is soliciting comments on several areas including future plans to group HH PPS claims centrally during claims processing, updates to the HH Value-Based Purchasing Model, and HH quality reporting.

Now…if you have read the proposed rule or reviewed any good summaries you know that two of the items I just listed are pure fiction…but most of you probably have not, and therefore I am not going to tell you which two I made up.By the way…did you happen to catch number 10?That one is real I assure you.Did you comment on the rule?Probably not…how would I know that?Because as of Midnight EST on Friday, August 26 only 84 online comments had been posted.I said 84.Just 84.I am hopeful that many more comments were submitted in letter form to CMS directly at the address they provided, but I am not overly confident that the number exceeds the online total.By contrast the Animal and Plant Health Inspection Service (apparently that is really a thing) published a proposed rule on July 26th and the comment period closes on September 26th.Still a month away from the close of that comment period and already this rule that creates new guidelines for inspecting horses at auctions and horse shows has over 2,300 comments.

I love horses, but home health agencies, patients and clinicians are more important.There are over 12,000[1] home health agencies in the US that employ upward of 500,000[2]clinicians and staff to serve roughly 3.5 million[3] patients a year.Yet a rule that profoundly impacts us all received only 84[4] online comments.The math does not add up to me.Commenting on these rules is our opportunitity to have a voice in the decision making process.We failed this year, again.Let’s not let it happen next year.I love horses, but this is ridiculous.

By Bud Langham

Bud Langham, PT, MBA is the Chief Clinical Officer at Encompass Home Health and Hospice based in Dallas, TX.He is an APTA and Home Health Section member as well as a former Federal Affairs Liaison.You can contact him at blangham@ehhi.com or follow him on twitter at @budlangham.

[1] MedPAC June 2016

[2] Partnership for Quality Home Healthcare

[3] MedPAC June 2016

[4] www.regulations.gov

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