Beyond Rebasing: Other Elements in the HHPPS Final Rule
December 3, 2013 09:23 AM
In the final rule for the home health prospective payment system (HHPPS), the Centers for Medicare & Medicaid Services (CMS) finalized changes it proposed to the home health Grouper by eliminating the 170 diagnosis codes claiming that reporting these diagnosis codes for home health is not compliant with ICD-9 coding guidelines. CMS’ maintains that these conditions are less acute or resolved prior to a home health admission (category 1), or the condition does not impact the home health plan of care or result in additional resource utilization (category 2).
As stated in comments to the proposed rule, the National Association for Home Care & Hospice disagrees with CMS’ assumption and believes there are instances where it is appropriate to list several of these diagnosis in accord with ICD-9 coding guidelines are receive case mix points.
Additionally, NAHC argued that changes in case mix points related to the elimination of the diagnoses should be done in a budget neutral manner. CMS, in the final rule, did reduce the amount of the adjustment to the case mix weights to accommodate for the elimination of these codes from the HHPPS.
CMS also finalized two new claims based quality measures:
Rehospitalization during the first 30 days of home health
Emergency Department Use without Hospital Readmission during the first 30 days of home health
The new measures apply to only those patients that have been discharged from the hospital within 5 days prior to admission and measures rehospitalizations and emergency department use within the first 30 days of the SOC date.
Although the new claims-based measures have not been endorsed by the National Quality Forum (NQF), CMS has made some adjustment to the risk adjustment model and plans to submit the measures to the NQF for endorsement by December 6, 2013.
Agencies should expect to see the measures reported at the agency level sometime in 2014 and posted for public reporting on Home Health Compare in 2015.
The measures are in addition to the current collected claims based measures for acute care hospitalization and emergency department use without hospitalization. These current measures apply to all Medicare home health patients admitted to the hospital or who use the emergency department in the first 60 days from admission to home health.
Furthermore, CMS has finalized the elimination of stratification by episode length for the process measures. Currently there are 97 quality measures included on the CASPER reports, of which 45 are process measures. This reduction will decrease the total number of home health quality measures to 79 and reduce the number of process measures from 45 to 27. This will remove 18 process measures from the current CASPER reports. Home Health Compare will report measures for all episodes rather than short episodes. CMS received no comments in opposition to this action.
Lastly, CMS finalized its proposal to ensure that state Medicaid programs include explicit provision to contribute to the cost of HHA surveys with the costs that are attributable to Medicare and Medicaid shared on a 50/50 basis between the two programs.
To view the final rule click here