Surviving The 2024 Home Health Proposed Rule
The Centers for Medicare and Medicaid Services (CMS) has released the Calendar Year (CY) 2024 Home Health Prospective Payment System Proposed Rule (HH PPS), which includes significant changes in reimbursement, including deep cuts.
According to the suggested policies, CMS predicts that overall Medicare payments to HHAs in CY 2024 will drop by $375 million, or 2.2 percent, from CY 2023. This cut to Medicare payments could lead to higher out-of-pocket costs for beneficiaries, and the change to the way home health agencies are paid for therapy services could make it more difficult for them to provide care to patients.
Key Changes
The CY 2024 HH PPS Proposed Rule, released on June 30, 2023, by the CMS, proposes a number of changes to the way Medicare pays for home health services.
Decrease overall Medicare payments to home health agencies by 2.2%, or by $375 million compared to CY 2023. This decrease is due to a number of factors, including the recalibration of the PDGM case-weights, the rebasing of the home health market basket, and updates to the labor-related share.
A permanent, prospective adjustment to the CY 2024 home health payment rate to account for the impact of the implementation of the Patient-Driven Groupings Model (PDGM). This adjustment would reduce payments by 5.653%.
Changes to the way negative pressure wound therapy (NPWT) is reimbursed under Medicare. CMS is proposing to create a separate payment for the disposable device used in NPWT, starting January 1, 2024. Payment for the services to apply the device will still be included under the home health prospective payment system.
Changes to the Home Health (HH) Quality Reporting Program (QRP) beginning with the CY 2025 HH QRP. They are proposing to adopt two new measures, remove three measures, and publicly report four measures. They are also proposing technical changes to § 484.245(b), seeking input on future HH QRP measure concepts, and providing updates on HH QRP health equity initiatives.
Preparing for Change
While the rule will not be finalized until November 2023, it's important for providers to understand the proposed rule's content and prepare for potential changes. These changes are likely to have a significant impact on the home health industry.
Agencies will need to find ways to reduce costs and improve efficiency in order to offset the impact of the cuts. For providers, this is the ideal time to organize their affairs and begin making plans for potential future financial setbacks.
Here are some survival strategies that home health agencies can consider:
Focus on Home Health Value-Based Purchasing (HHVBP) Model. Use the information from reports and create a plan to see where improvements can be made. That may include providing additional staff training or ensuring clinical managers are doing the right thing.
Focus on high-need patients. Agencies can improve their financial performance by focusing on patients with the highest needs. These patients are more likely to require more services, which can lead to higher reimbursement.
Optimize care coordination. Agencies can reduce costs by improving care coordination between their staff and patients' other healthcare providers. This can help to avoid duplication of services and ensure that patients are receiving the care they need in the most efficient way possible.
Invest in technology. Technology can help home health agencies improve efficiency and reduce costs in a number of ways. For example, agencies can use technology like remote care monitoring, home safety technology devices, or cardiac monitoring technology to help improve patient supervision when there is no professional present at home.
However, it's important that agencies still thoroughly assess the electronic medical record software they already use to make sure these connections are suitable.
Conclusion
The proposed changes to the HH PPS are significant and will have a major impact on home health agencies. The decrease in overall payments, the permanent prospective adjustment, and the changes to the value-based purchasing model will all put pressure on home health agencies to reduce costs and improve efficiency.
It's important for HHAs to understand these proposed rules so they can prepare for potential changes and impacts. Having the right support in areas such as documentation compliance can help HHAs succeed and remain resilient in the face of changing industry landscapes.
QAnnovate’s team of quality assurance professionals is here to help you prepare for the challenges that the proposed rule presents. Get in touch with us today for any inquiries or for a FREE trial.