Proposed 2015 PPS rule would trim payments, ease face-to-face requirement

Proposed 2015 PPS rule would trim payments, ease face-to-face requirement
by: Burt Schorr
Published Jul 1, 2014
Last Reviewed Jul 1, 2014
Home health reimbursement would drop by a fraction, but agencies would gain considerable face-to-face relief under the PPS rule CMS is proposing for calendar year 2015.

As announced July 1, the rule anticipates a 2.2% inflation update offset by the second year of rebasing adjustment to the standardized 60-day episode rate, LUPA rates and rates for non-routine medical supplies. The net effect would be a $58 million, or 0.30%, cut in Medicare payments. The calculations don’t include the 2% sequestration reduction currently in effect through March 2015 for all Medicare providers.

In addition to the reimbursement changes, CMS is proposing the following to the face-to-face encounter requirements:
Eliminate the controversial requirement that certifying physicians provide a narrative in their own words explaining why the patient is eligible for home health. The certifying physician still would be required to certify that a face-to-face patient encounter occurred and to document the date of the encounter.
Limit medical reviews to medical records from the patient’s certifying physician or from the discharging facility when determining initial eligibility for the home health benefit.
Disallow certification and re-certification claims by physicians when the agency claim is denied on grounds that the patient was ineligible for home health.
CMS also clarified that the face-to-face encounter requirement applies to the physician’s certification only, not the re-certification of eligibility for subsequent episodes.

More proposed changes:
Case-mix weight. CMS proposes to recalibrate case-mix weights using the most current cost and utilization data.
Therapy reassessment timeframes. Therapy reassessments would occur every 14 calendar days rather than before the 14th and 20th visits and once every 30 calendar days.
Quality reporting and OASIS submission requirements. CMS would establish a minimum submission threshold for the number of OASIS assessments that each agency must submit. Beginning in CY 2015, the initial compliance threshold would be 70% and will increase by10% increments over the next two years to reach a maximum threshold of 90%.
Speech language pathologists. CMS is proposing to revise the Home Health Conditions of Participation (CoPs) for speech language pathologist (SLP) personnel by replacing current stringent requirements with a more flexible option that defers to state-licensure requirements.
Value-based purchasing. The home health model being considered would include a 5% to 8% adjustment in payment made after each planned performance period in the projected five to eight states. — Burt Schorr (

You can view the complete rule at:

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