Final Home Health Rules and Interpretive Guidance: Proposed Payment Model Rescinded

CMS published the 2018 Home Health Prospective Payment System final rule on November 7, 2017.
A broadly challenged proposed new payment system (Home Health Groupings Model, or HHGM) was not finalized. As we note in a previous CMA Alert, HHGM would have provided home health agencies further disincentives to serve people with longer-term chronic conditions.  The proposed payment system would have paid agencies more money for a brief amount of care, and paid less after 30 days.  In addition, it would have paid agencies more money when a patient started home health care within 14 days of discharge from an institution, such as a hospital, and paid less if a patient was not first an inpatient prior to starting home health care.
Unfortunately, discriminatory Value Based Purchasing Models and Quality Reporting Requirements were advanced in the final rule.  Such measures promote disparity and create barriers against fair access to home care benefits for the most vulnerable Medicare beneficiaries.

CMS also published Draft Interpretive Guidelines for new Home Health Conditions of Participation in the Medicare and Medicaid programs.  The guidelines will become effective January 13, 2018.  Further analysis of the new Conditions of Participation and the Interpretive Guidelines will be forthcoming in a future CMA Alert.