FINAL RULE CY2015 has been released

On October 30, 2014, at 4:30 pm, CMS released its unpublished FINAL RULE for CY2015 Home Health PPS Update, Home health quality reporting requirements and survey and enforcement requirements for home health agencies.

This rule updates the PPS rates for the national, standardized 60-day episode payment rates, national per-visit rates, and the non-routine medical supply conversion factor and becomes effective for episodes ending ON or AFTER January 1, 2015.

The Final Rule also implements changes to simplify the face-to-face encounter regulatory requirements, changes to the HH PPS case-mix weights, changes to the quality reporting program requirements, changes to simplify therapy reassessment timeframes, a revision to qualification for the Speech-Language Pathologist, minor technical regulation text changes, and limitation on the review ability of the civil monetary penalty provision.

The rule also discusses Medicare coverage of insulin injections, the delay in implementation of ICD-10-CM, and a HH value-based purchasing model.

This is what CMS is implementing regarding rebasing adjustments:  reduce the national, standardized 60-day episode payment amount by $80.95, increase the national per-visit payment amounts by 3.5% of the national per-visit payment amounts in CY2010 with the increases ranging from $1.79 for home health aide services to $6.34 for medical social services as described in section II.C, and reduce the NRS conversion factor by 2.82%.

For the face-to-face (F2F) encounter, the narrative requirement has been adjusted and the process will be that the physician and/or acute/post-acute care facility must (1) establish the patient was eligible for the home health benefit; and (2) demonstrate that the face-to-face encounter was related to the primary reason the patient requires home health services, occurred within the required timeframe, and was performed either by he certifying physician, an acute/post-acute care physician that cared for the patient in that setting, or allowed non-physician provider.  In addition the above changes, associated physician claimed for certification/re-certification of eligibility (patient not present) will note be eligible to be paid when a patient does not meet home health eligibility criteria.  The F2F encounter requirement is applicable for all episodes initiated with the completion of a Start-of-Care OASIS assessment, which is considered certification, not re-certifications.

The Home Health Quality Reporting program update establishes a minimum submission threshold for the number of OASIS assessments that EACH agency must submit.  Beginning CY2015, initial compliance threshold will be 70% and will increase by 10% increments over the next two years to reach the maximum threshold of 90%!

Please take the time to download and review the final rule, pre-released PDF, at  FINAL Rule @ the Public Inspection Desk.

Sincerely,

Kimberly

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