Home Health & Hospice

CMS' 2015 HH PPS proposed rule to eliminate face-to-face physician narrative

Homecare Insider, July 7, 2014

CMS’ proposed rule for calendar year (CY) 2015, released July 1, carries mixed news for homecare providers: it aims to both nix the contentious narrative component of the physician face-to-face encounter requirement and whittle down Medicare payments to home health agencies by .3%, or $58 million.

According to the official CMS fact sheet, the projected payment rate is the sum of the 2.2%, or $427 million, adjusted home health payment increase and a $485 million overall decrease based on rebasing adjustments to (1) the national, standardized 60-day episode payment rate, (2) the national per-visit payment rates, and (3) the non-routine medical supplies conversion factor.
 
On the face-to-face front, CMS is proposing three changes to address widespread disapproval surrounding its enforcement of the Affordable Care Act mandate. The most significant of these changes is the organization’s desire to eliminate the physician narrative component of the encounter documentation. In its place, the fact sheet specifies that HHAs must supply a revised certification form to physicians, who will use it to verify that a face-to-face encounter occurred and to document the date of the visit.
 
Additional changes include a proposed update to the home health quality reporting program that would establish a minimum threshold for the number of OASIS assessments that each HHA must submit to avoid reductions in annual payment updates (APU). The initial compliance threshold would require agencies to submit admission and discharge assessments for a minimum of 70% of all patients with episodes of care occurring during that reporting period. The threshold would then increase in 10% increments over the next two years until a maximum threshold of 90% is reached in CY 2017, at which time an agency’s noncompliance would affect its APU.
 
Finally, inspired by its successful implementation of the Hospital Value-Based Purchasing (VBP) program, CMS is considering testing a VBP model for HHAs beginning in CY 2016. According to fact sheet, the prospective model would include a 5-8% adjustment (increase or decrease) in Medicare payments to HHAs in the five to eight states expected to participate, based on their quality of performance, thereby providing “an opportunity to test whether significantly larger incentives would lead to higher quality of care for beneficiaries.”
 
CMS will accept comments on the proposed rule until September 2, 2014.