The Final Rule for 2015 Medicare HHPPS payment rates was released by CMS late Thursday afternoon. CMS also finalized some of the other proposals - including eliminating the physician narrative to the face-to-face requirements.
Below is a quick summary of the Final Rule, along with preliminary analysis from NAHC staff in bold. A more detailed analysis of the final HHPPS rule will be available once NAHC staff has more time to review the rule in its entirety.
1. CMS eliminates the physician narrative requirement that has plagued physicians and home health agencies. GREAT NEWS
2. CMS keeps its widely-panned proposal to require physicians to have sufficient documentation in their own files to support the certification of homebound status and skilled care need. However, CMS will permit HHAs to provide their record to the certifying physician so that it can be included in considering whether sufficient documentation exists to support the certification. Also, CMS modifies the rule to require that certifying physicians supply their records to the HHAs whenever a claim is audited for compliance. This may be a problem still. SLIGHT IMPROVEMENT OVER PROPOSED RULE
3. Rate rebasing continues with an $80.95 base episode rate reduction offset by a 2.1% inflation update (2.6 MI minus 0.5 productivity adjustment) along with the second –year adjustments to LUPA and NRS rates. The productivity adjustment is 0.1% greater than proposed leading to a slightly lower inflation update—2.1 vs. 2.2 proposed. AS EXPECTED
4. CMS maintains its proposed across-the-board recalibration of case mix weights. HHA must include this change in any evaluation of the payment rate reductions as the weights are dramatically different than 2014 HRRGs. CLEARER EXPLANATION OF CHANGE
5. The proposed new wage index that is a 50/50 blend of the new CBSA designations is included for 2015. CMS limits the rural add-on to counties that are “rural” under the new CBSA geographic area designations only. Over 100 counties will lose the add-on as a result. CONSISTENT WITH PREVIOUS CBSA CHANGE, BUT STILL UNFORTUNATE
6. CMS eliminates 13th and 19th visit professional therapist evaluations and replaces that requirement with assessments every 30 days. CMS had proposed a 14 day reassessment requirement. GOOD NEWS
7. Miscellaneous other proposals are finalized regarding OASIS submissions, speech-language pathologist qualifications, civil monetary penalties for CoP violations, and recertification requirements that will increase the number of F2F situations.
Overall, the Final Rule is a slight improvement over the proposed version. The changes to the F2F requirements are most welcome along with the modifications on the therapy assessment requirements.
More detailed review will be forthcoming as NAHC staff digests the 259 page rule.
The Rule is available here.