CMS Releases Final Rule on 2015 Home Health PPS Rates
Physician narrative eliminated for face-to-face requirements
CMS released the final rule on the 2015 Home Health PPS Rates on October 30, including several slight improvements over the proposed version. The most positive determinations for the home health industry include changes to the face-to-face requirements and modifications on the therapy assessment requirements. Additional determinations were made regarding OASIS submissions, speech-language pathologist qualifications, civil monetary penalties for Conditions of Participation violations, and recertification requirements that will increase the number of face-to-face situations.
Following a more detailed review of the 250-page rule, Simione Healthcare Consultants will issue additional updates in newsletter articles and other communication. If you have questions regarding these and other related determinations, please contact us at 844.215.8820 or [email protected]
- Good news for physicians and home health agencies – CMS has eliminated the requirement for the physician narrative.
- CMS will sustain the requirement that physicians have sufficient documentation in their own files to support the certification of homebound status and need for skilled care. CMS will permit home health agencies to provide their records to certifying physicians for consideration of whether sufficient documentation of certification exists; however, CMS has modified the rule to require that certifying physicians supply their records to home health agencies whenever a claim is audited for compliance. While this determination is an improvement over the proposed rule, it may still be problematic for providers.
- As expected, rate rebasing will continue with an $80.95 base episode rate reduction offset by a 2.1% inflation update (2.6 minus 0.5 productivity adjustment) along with the second-year adjustments to LUPA and NRS rates. The final productivity adjustment of 2.1 is 0.1% higher than the proposed 2.2%, leading to a slightly lower inflation update.
- There is greater clarity of CMS’s proposed across-the-board recalibration of case mix weights. Home health agencies must include this change in any evaluation of the payment rate reductions, as the weights are dramatically different than 2014 HRRGs.
- The proposed new wage index – a 50/50 blend of the new CBSA designations – applies for 2015. Unfortunately, CMS has limited the rural add-on to counties that are “rural” under the new CBSA geographic area designations only. More than 100 counties will lose the add-on as a result.
- Thankfully, CMS has eliminated the 13th- and 19th-visit professional therapist evaluations, replacing this requirement with assessments every 30 days instead of the proposed 14-day reassessment requirement.