Based upon feedback and efforts from the home health industry and other key stakeholders, the Centers for Medicare and Medicaid Services (CMS) decided not to finalize implementation of the Home Health Groupings Model (HHGM) in the CY 2018 Home Health Prospective Payment System final rule, released last Wednesday, November 1st. HHGM was the centerpiece of the proposed rule regulation and would have drastically changed care delivery and payment, moving to 30-day episodes and cutting an estimated $950 million in reimbursement.

While this is a encouraging step for the numerous individuals and organizations who wrote letters and reached out to CMS and policymakers with their concerns about the model, it is important to note that HHGM was not withdrawn, but simply not finalized. Per CMS’s own language in the final rule, “We are not finalizing the implementation of the HHGM in this final rule. We received many comments from the public that we would like to take into further consideration.”

There are ongoing legislative efforts surrounding HHGM, of which the Alliance is continuing to stay abreast. Additionally, as stated in our comment letter, the Alliance welcomes the opportunity to work with CMS further on a patient-centered model of care that puts the patient first and does not threaten access nor quality.

HHGM, however, wasn’t the only component of the proposed rule. CMS finalized a number of changes outlined in the proposed rule, including a reduction to the national, standardized 60-day episode payment rate for CY 2018 of 0.97 percent and case-mix weight adjustments.

Though nowhere near the cuts projected had HHGM been implemented, CMS does project an overall reduction of 0.4 percent in payments to HHAs or -$80 million for CY2018 in the final rule.

Additional changes for implementation included in the final rule relate to Home Health Value Based Purchasing Model (HHVBP) and the Home Health Quality Reporting Program (HHQRP).

The final rule amends the definition of “applicable measure” in HHVBP to mean a measure for which an agency has at least 40 completed surveys  for HHCAHPS. Additionally, the final rule finalizes the removal of the OASIS-based measure, Drug Education on All Medications Provided to Patient/Caregiver during All Episodes of Care, from the set of applicable measures.

While CMS did finalize some of the proposed changes to QRP, CMS decided not to finalize three of the categories for standardized patient assessment data elements in QRP: Cognitive Function and Mental Status; Special Services, Treatments, and Interventions; and Impairments.

The changes to QRP finalized within the rule include the replacement the current pressure ulcer measure, Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short Stay) (NQF #0678), with a modified version of that measure entitled, Changes in Skin Integrity Post- Acute Care: Pressure Ulcer/Injury, effective starting with the CY 2020 HH QRP. Further, CMS finalized the removal of 235 data elements from 33 current OASIS items, effective with all HHA assessments on or after January 1, 2019.

A copy of the final rule is available through the Federal Register here, and you can read the Alliance’s comments to CMS on the proposed rule here.

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