Overall CMS proposed changes to the home health PDGM payment system for 2021 are minimal compared to what we are accustomed to over the past 10 years or so. Given there is minimal reportable data for PDGM at this point and the fact that we are involved in a Public Health Emergency this is welcome relief for our industry. Nevertheless, there are few notable changes that our industry partners and friends should be aware of.
PDGM Case Weights & LUPA Thresholds – Proposed to remain at FY 2020 levels – no changes.
Wage Index– Please do not miss the potential impact of this major change proposed for 2021. CMS proposes to adopt the new OMB delineations which are based on 2010 census data. The effect could be significant for your agency as the CBSA lines have moved. You may be designated “rural” for 2020 and be changed to an “urban” designation in 2021 or vice versa. The potential impact of this proposal is so significant that CMS proposes to cap any wage index increases at 5 percent. If your wage index drops by 5% it will yield a significant drop in you agency specific national rate for payment purposes.
Payment Rate Update – CMS proposes a net 2.7% increase to the National Standardized 30-day payment period amount. Providers that submit required quality data will see an increase from $1,864.03 (2020) to $1,911.87. Providers that do not submit required quality data will have their payments rated reduced by 2%. The LUPA Per Visit Rates are also proposed to increase by 2.7%. The rural add-on payment continues to be phased out with High Utilization category receiving No add-on in 2021. The Low population density category with 2% and the “all other” category 1%. The Outlier Fixed Dollar Loss Ratio (FDL) is proposed to remain at .63.
Home Infusion Therapy – Effective January 1, 2021 the transition of Home Infusion Therapy to a new Medicare benefit category will take place. This new benefit covers the professional services, including nursing services furnished in accordance with the plan of care, patient training and education not otherwise covered under the DME benefit, remote monitoring and monitoring services for the provision of home infusion therapy and home infusion drugs furnished by a qualified home infusion therapy supplier. The home health CoP’s will be revised to remove payment for home infusion therapy under our PDGM system. Please note that home health agencies may make application to become a home infusion supplier under Part B and may continue to provide services but will bill as a Part B provider and not as part of the home health 30-day PDGM payment. Notable is that homebound is not a requirement for a beneficiary receiving home infusion therapy plus CMS has clarified that the beneficiary may receive skilled home health services and the home infusion benefit simultaneously. The services may be provided by the same provider or it may be two different providers. If you are a home health agency that desires to continue providing home infusion therapy into 2021 the time to act is NOW. Please note that you will be required to enroll by completing the CMS 855B and will be required to pay required enrollment fees as per the rules that govern institutional providers.
Telehealth and remote patient monitoring – CMS is proposing to make the allowances provided for telehealth and remote patient monitoring during the Public Health Emergency permanent. These services will need to be clearly outlined in the home health plan of care. They will also need to be tied to patient-specific needs and facilitate the achievement of goals. There is still no proposed reimbursement being considered for telehealth services. Unfortunately, they cannot substitute for visits that need to be made in person for reimbursement. The rule does propose to allow HHAs to report the costs of telecommunications technology as allowable administrative costs on the home health agency cost report outside of the public health emergency.
2022–NOA’s- Notice of admissions – In 2021 home health agencies will be required to submit “No-Pay” RAP’s. While the billing process will remain the same the requirements for home health to submit the RAP will change. Basically, a signed physician order or verbal approval to initiate care signed by the agency RN and completion of the assessment visit are the only requirements to submit the RAP. In 2022 the RAP process will and replaced with a notification of admission (NOA). Please note that the No-Pay RAP’s like the NOA will be required to be submitted within five-days of admission. Penalties for late submission will be harsh as you will give up 1/30th of the 30-day payment amount for each day the submission is late.
We appreciate all our current clients and look forward to partnering with many more of you to help you Navigate the Complexities of Compliance in our highly regulated environment. Please let us know how we can service your needs.