Summary of CMS Open Door Forum for Home Health

NAHC Report

On November 29, 2923, the Centers for Medicare & Medicaid Services (CMS) held the Home Health, Hospice, and DME Open Door Forum. Below are key updates that provided for home health providers. Tomorrow, we will feature the summary for hospice providers. (GO HERE for the summary for hospice providers.)

Calendar year 2024 Home Health Final Rule update

Payment Update

On November 1, 2023, the CMS issued the calendar year (CY) 2024 Home Health Prospective Payment System (HH PPS) Rate Update final rule, which updates Medicare payment policies and rates for Home Health Agencies (HHAs). This rule includes routine updates to the Medicare Home Health PPS payment rates for CY 2024 in accordance with existing statutory and regulatory requirements. 

CMS is finalizing a permanent prospective payment adjustment to the home health 30-day period payment rate. The finalized -2.890 percent permanent adjustment is half the full permanent adjustment of -5.779 percent (-5.653 percent in the proposed rule). Medicare payments to HHAs in CY 2024 will increase in the aggregate by 0.8 percent, rather than decrease by 2.2 percent as proposed.

CMS finalized its proposals to rebase and revise the home health market basket and revise the labor-related share. For CY 2024, CMS will adopt a 2021-based home health market basket, which includes changes to the market basket cost weights and price proxies.

CMS recalibrated the case-mix weights and low utilization payment adjustment (LUPA) thresholds using the most complete utilization data available at the time of rulemaking. 

Disposable Negative Pressure Wound Therapy

In accordance with Division FF, section 4136 of the Consolidated Appropriations Act (CAA), 2023, CMS is finalizing its proposal to codify statutory requirements for negative pressure wound therapy (NPWT) using a disposable device for patients under a home health plan of care. The CAA, 2023 requires that beginning January 1, 2024, there is a separate payment for the device only. Payment for the services to apply the device is to be included in the 30-day payment under the home health prospective payment system. There are also changes that allow HHAs to now report the disposable device on the type of bill 32x.

Home Health Quality Reporting Program (HHQRP)

CMS is finalized the following for the CY 2025 HH QRP

  • Two new measures
  • Removed one existing measure
  • Removed of two OASIS items 
  • Begin public reporting of four measures in the HH QRP
  • Updates on closing the health equity gap
  • Codifying into regulation the 90 percent data submission threshold policy

Expanded Home Health Value-Based Purchasing (HHVBP) Model 

For the expanded HHVBP Model, CMS is finalized its proposals to:

  • Codify in the Code of Federal Regulations the measure removal factors finalized in the CY 2022 HH PPS final rule;
  • Replace the two Total Normalized Composite Measures (for Self-Care and Mobility) with the Discharge Function Score measure effective January 1, 2025;
  • Replace the OASIS-based Discharge to Community (DTC) measure with the claims-based Discharge to Community-Post Acute Care (PAC) Measure for Home Health Agencies, effective January 1, 2025;
  • Replace the claims-based Acute Care Hospitalization During the First 60 Days of Home Health Use and the Emergency Department Use without Hospitalization During the First 60 Days of Home Health measures with the claims-based Potentially Preventable Hospitalization measure effective January 1, 2025;
  • Change the weights of individual measures due to the change in the total number of measures; and
  • Beginning with performance year CY 2025, update the Model baseline year to CY 2023 for all applicable measures in the finalized measure set, including those measures included in the current measure set with the exception of the 2-year DTC-PAC measure, which would be CY 2022 and CY 2023.

CMS reminded participants that the October Interim performance reports are available and encouraged HHAs to review their reports. CMS also reminded participants of the many resources on the Expanded HHVBP website. 

Appeals Process

CMS finalized an additional opportunity to request a reconsideration of the annual Total Performance Score (TPS) and payment adjustment. 

CMS reminded participants that public reporting of HHVBP performance data and payment adjustments will begin in December 2024.   

Home IVIG

CMS is finalizing regulations, as proposed, to implement permanent coverage and payment of items and services related to administration of IVIG in a patient’s home for a patient with a primary diagnosis of immune deficiency disease (PIDD). Currently, Medicare pays for the IVIG product using the average sales price (ASP) methodology. Payment for items and services needed for in-home administration of IVIG for the treatment of PIDD for CY 2024 is set at $419.25.

Home Health Consumer Assessment of Health Providers and Systems (HHCAHPS)

CMS announced that registration is open for the 2024 HHCAHPS survey vendor update webinar training session. Survey vendors who wish to retain their status as approved HHCAHPS Survey vendors must have their designated HHCAHPS Survey Project Manager attend the entire session. Registration closes at 9:00 PM Eastern Time on January 30, 2024. Participants were reminded that January 18, 2023 is the 3rd quarter 2023 data submission deadline.